G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. PERFECTO

FACTS

Accused-appellant Juan Dela Cruz was charged with the crime of Robbery with Homicide under Article 294 of the Revised Penal Code. The prosecution alleged that on January 15, 2015, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the commission of the robbery, Dela Cruz allegedly stabbed Santos, causing his death.

The prosecution presented eyewitness Maria Santos, the victim’s wife, who testified that she saw Dela Cruz inside their house, holding a knife and taking valuables before stabbing her husband. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a fiesta at the time of the incident.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi can prevail over positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated in the crime of robbery.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.

The Court held that the positive identification of the accused by eyewitness Maria Santos was clear, consistent, and credible. She had no motive to falsely testify against Dela Cruz. Her testimony was corroborated by physical evidence and the recovery of stolen items in the possession of the accused. The defense failed to impeach her credibility or show any ill motive.

2. The defense of alibi cannot prevail over positive identification.

Alibi is inherently weak and must be supported by credible evidence showing the physical impossibility of the accused being at the scene of the crime. Dela Cruz failed to prove that it was impossible for him to be at the crime scene. The distance between the fiesta location and the victim’s house was not insurmountable, and no convincing evidence was presented to substantiate the alibi.

3. The qualifying circumstance of homicide was properly appreciated.

Robbery with Homicide is a special complex crime where the homicide may be committed before, during, or after the robbery. The prosecution established that the killing was intimately connected to the robbery, as it was done to facilitate the taking of valuables or to eliminate witnesses. The trial court correctly appreciated the qualifying circumstance.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan Dela Cruz for the crime of Robbery with Homicide is AFFIRMED. Costs against accused-appellant.

SO ORDERED.