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

Ponente: J. PERFECTO

FACTS

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, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and witnessed the stabbing. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a fiesta at the time of the incident.

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

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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 the positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated to convict the accused of Robbery with Homicide.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Supreme Court AFFIRMED the conviction. The prosecution successfully established the elements of Robbery with Homicide:

– Taking of personal property belonging to another proven by the testimony of Maria Santos and the missing cash and jewelry.
– Unlawful taking with intent to gain evident from the forcible entry and asportation.
– Violence or intimidation against a person the stabbing of Pedro Santos.
– Homicide committed by reason or on occasion of the robbery the killing was intimately connected to the robbery, as it was done to facilitate the taking or to eliminate a witness.

The Court held that the positive identification by Maria Santos, who had no ill motive to falsely testify, was clear, consistent, and credible. Her testimony was corroborated by the physical evidence and the autopsy report.

2. On the defense of alibi.

The defense of alibi cannot prevail over the positive identification of the accused. Alibi is inherently weak and easily fabricated. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime was committed but also that it was physically impossible for him to be at the crime scene. The accused failed to establish physical impossibility, as the fiesta he attended was in a neighboring city, still accessible within hours.

3. On the qualifying circumstance of homicide.

The Court ruled that homicide was properly appreciated as a qualifying circumstance. The killing was done on the occasion of the robbery; the violence employed was to carry out the robbery or to eliminate opposition. The single indivisible crime of Robbery with Homicide was proven, warranting the penalty of reclusion perpetua under Article 294(1) of the Revised Penal Code.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz for the crime of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.