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 before fleeing with cash and jewelry.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz enter the victim’s house and later flee. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. The trial court found the prosecution’s evidence credible and convicted Dela Cruz, sentencing him to reclusion perpetua without eligibility for parole. Hence, this appeal.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should prevail over the positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated in the crime of robbery.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.
The Court affirmed the trial court’s findings. The eyewitness testimony of Maria Reyes was clear, consistent, and credible. She positively identified Dela Cruz as the perpetrator, and her testimony was corroborated by physical evidence and the recovery of stolen items in Dela Cruz’s possession. The defense failed to show any ill motive on the part of the witness to falsely testify.

2. The defense of alibi cannot prevail over positive identification.
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 impossibility. The distance between the crime scene and his alleged location was not insurmountable, and no credible witnesses corroborated his alibi. Positive identification by a credible witness trumps alibi.

3. The qualifying circumstance of homicide was properly appreciated.
The prosecution established that the killing occurred by reason or on occasion of the robbery. The intent to rob was evident from the stolen items, and the homicide was a direct consequence of the robbery. Thus, the crime was correctly classified as Robbery with Homicide under Article 294 of the Revised Penal Code.

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DISPOSITIVE PORTION

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 without eligibility for parole is AFFIRMED. Costs against accused-appellant.

SO ORDERED.