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, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented eyewitness testimony from Maria Santos, the victim’s wife, who identified Dela Cruz as the perpetrator. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in a different city 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’s 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 positive identification by an eyewitness.
3. Whether the qualifying circumstance of use of a deadly weapon was properly appreciated.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.
The Supreme Court held that the positive identification by eyewitness Maria Santos was credible, consistent, and categorical. She had a clear view of the accused during the incident, and there was no ill motive attributed to her that would impel her to falsely testify. The Court emphasized that positive identification, when credible, prevails over alibi and denial.

2. The defense of alibi cannot prevail over positive identification.
The defense of alibi is inherently weak and must be supported by clear and convincing evidence that the accused was so far away that it was physically impossible for him to be at the crime scene. Dela Cruz failed to prove this physical impossibility. Moreover, alibi becomes even less credible when there is positive identification by a credible witness.

3. The qualifying circumstance of use of a deadly weapon was properly appreciated.
The use of a knife, a deadly weapon, was integral to the commission of the crime. It was used to consummate the robbery and cause the death of the victim. Hence, the crime was properly qualified as Robbery with Homicide 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.