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, 2015, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the robbery, Dela Cruz stabbed Santos, causing his death. 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 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 homicide was properly appreciated in the crime of robbery.

RULING

1. On the proof of guilt beyond reasonable doubt.
The Supreme Court held that the prosecution successfully proved the guilt of the accused beyond reasonable doubt. The eyewitness testimony of Maria Santos was clear, consistent, and credible. She positively identified Dela Cruz as the person who entered their house, demanded money, and stabbed her husband. The Court emphasized that positive identification, when credible and categorical, prevails over alibi and denial.

2. On the defense of alibi.
The defense of alibi 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 scene of the crime. Dela Cruz failed to prove this impossibility. The place where he claimed to be was only a few hours away from the crime scene, making it not physically impossible for him to have committed the crime. Hence, alibi cannot prevail over positive identification.

3. On the qualifying circumstance of homicide in robbery.
For robbery with homicide to be convicted, the prosecution must prove: (a) the taking of personal property with intent to gain; (b) the taking was with violence or intimidation against a person; and (c) the homicide was committed by reason or on occasion of the robbery. All these elements were present. The killing of Pedro Santos was inseparable from the robbery, as it was committed to facilitate the taking of property or to eliminate witnesses. Thus, the crime was properly classified as robbery with homicide.

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DISPOSITIVE PORTION

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

SO ORDERED.