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

Ponente: J. Reyes

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, 2015, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the commission of the robbery, Dela Cruz stabbed Santos, causing his death. The prosecution presented eyewitness testimony from Maria Santos, the victim’s wife, who positively 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. Dela Cruz appealed to the Supreme Court via a petition for review on certiorari, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the eyewitness identification was unreliable.

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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.

RULING

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

The Supreme Court upheld the conviction. The Court emphasized that the positive identification of the accused by an eyewitness who had no ill motive to testify falsely is entitled to great weight. Maria Santos’ testimony was clear, categorical, and consistent. She had a good opportunity to see the perpetrator’s face during the well-lit incident and even recognized him as a former neighbor. The Court found no reason to doubt her credibility.

All elements of Robbery with Homicide were proven:
– Taking of personal property belonging to another (cash and jewelry were stolen).
– Unlawful taking with intent to gain.
– Use of violence or intimidation against a person (the stabbing).
– Homicide was committed by reason or on occasion of the robbery.

The defense’s claim of inconsistencies in the witness’s testimony pertained to minor details which did not affect the core narrative of the crime.

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

The Court reiterated the settled doctrine that 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 somewhere else when the crime was committed but also that it was physically impossible for him to have been at the crime scene. Dela Cruz failed to prove physical impossibility, as the city he claimed to be in was only a few hours away from the crime scene by vehicle.

Furthermore, alibi becomes even less credible when, as in this case, the accused is positively identified by an eyewitness who knew him prior to the incident.

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DISPOSITIVE PORTION

WHEREFORE, the petition is DENIED. 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 suffer the penalty of reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.