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

Ponente: J. Reyes

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, 2018, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, presented an alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the crime. The trial court found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua.

On appeal, Dela Cruz argued that the prosecution failed to prove his guilt beyond reasonable doubt, citing inconsistencies in the eyewitness’s testimony and the weakness of the evidence linking him to the crime.

ISSUE

Whether the trial court erred in convicting accused-appellant Juan Dela Cruz of Robbery with Homicide based on the evidence presented.

RULING

NO. The Supreme Court AFFIRMED the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide.

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RATIONALE

1. Credibility of Eyewitness Testimony
The Court held that the testimony of eyewitness Maria Reyes was credible, consistent, and corroborated by physical evidence. Minor inconsistencies in her testimony did not affect her overall credibility, as they pertained to trivial details and did not undermine the core of her account—that she saw Dela Cruz fleeing the crime scene with a bloodied knife.

2. Weakness of Alibi
The defense of alibi was rejected. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to have been at the crime scene. Dela Cruz failed to establish this impossibility. The distance between the crime scene and his alleged location was not insurmountable, making it possible for him to have committed the crime.

3. Proof Beyond Reasonable Doubt
The prosecution established all elements of Robbery with Homicide:
– Robbery: Taking of personal property with intent to gain through violence or intimidation.
– Homicide: Killing of a person, whether or not intended, provided it was committed by reason or on occasion of the robbery.
The evidence, including the eyewitness account and the recovery of stolen items from Dela Cruz’s possession, sufficiently proved his guilt beyond reasonable doubt.

4. Penalty
Under Article 294 of the Revised Penal Code, Robbery with Homicide is punishable by reclusion perpetua to death. In the absence of aggravating circumstances, the penalty of reclusion perpetua was correctly imposed by the trial court.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court, Branch 90, Quezon City, finding accused-appellant Juan Dela Cruz GUILTY of Robbery with Homicide and sentencing him to reclusion perpetua, is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.