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, 2010, Dela Cruz, armed with a knife, entered the house 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, who testified that she saw Dela Cruz fleeing from Santos’s house immediately after the incident. 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. Dela Cruz appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the eyewitness testimony was unreliable.

ISSUE

Whether the trial court erred in convicting accused-appellant Juan Dela Cruz of Robbery with Homicide based on the testimony of a lone eyewitness, despite alleged inconsistencies and the defense of alibi.

RULING

NO. The Supreme Court AFFIRMED the conviction of accused-appellant Juan Dela Cruz.

—

DOCTRINE

1. Credibility of Eyewitness Testimony: The testimony of a single eyewitness, if positive and credible, is sufficient to support a conviction. Inconsistencies on minor details do not impair the witness’s credibility but may even enhance it by showing that the testimony was not rehearsed.
2. Alibi as a Defense: Alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness. 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 have been at the crime scene.
3. Proof Beyond Reasonable Doubt: In criminal cases, the prosecution must prove the guilt of the accused beyond reasonable doubt. However, this does not mean absolute certainty; moral certainty is sufficient.

—

RATIONALE

1. Credibility of the Eyewitness: The Court found the testimony of Maria Reyes credible and consistent on material points. She positively identified Dela Cruz as the person she saw fleeing from the victim’s house. The alleged inconsistencies pertained to minor details (e.g., the exact time of the incident or the color of Dela Cruz’s shirt), which did not affect the substance of her testimony. The Court emphasized that witnesses are not expected to recall every detail with perfect accuracy, especially under stressful circumstances.

2. Weakness of the Alibi Defense: Dela Cruz failed to prove that it was physically impossible for him to be at the crime scene. The distance between the crime scene and the location of his alibi was not insurmountable, and no convincing evidence was presented to show that he could not have traveled between the two places. Alibi, being inherently weak, must yield to positive identification.

3. Proof Beyond Reasonable Doubt: The prosecution established all elements of Robbery with Homicide: (a) the taking of personal property with intent to gain, (b) with violence or intimidation against a person, and (c) the killing was committed on the occasion or by reason of the robbery. The eyewitness testimony, coupled with the circumstantial evidence (e.g., the stolen items found in Dela Cruz’s possession), provided moral certainty of his guilt.

4. Affirmation of the Penalty: The penalty for Robbery with Homicide under Article 294 of the Revised Penal Code is reclusion perpetua to death. Since no aggravating or mitigating circumstances were proven, the trial court correctly imposed reclusion perpetua in accordance with the Indeterminate Sentence Law and prevailing jurisprudence.

—

DISPOSITION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court convicting accused-appellant Juan Dela Cruz of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.