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 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 decision in toto. 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 can prevail over positive identification.
3. Whether the qualifying circumstance of homicide was properly appreciated.

RULING

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

The Court held that the prosecution successfully established all the elements of Robbery with Homicide:
– Taking of personal property belonging to another;
– With intent to gain (animus lucrandi);
– With violence or intimidation against persons;
– Homicide was committed by reason or on occasion of the robbery.

The eyewitness testimony of Maria Santos was clear, consistent, and credible. She had a direct view of the incident and knew Dela Cruz prior to the crime. Her testimony was corroborated by physical evidence and the recovery of stolen items in Dela Cruz’s possession.

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 impossibility. Moreover, positive identification by a credible witness prevails over alibi. The Court found no ill motive for Maria Santos to falsely testify against Dela Cruz.

3. The qualifying circumstance of homicide was properly appreciated.

Homicide is deemed inherent in the crime of Robbery with Homicide when the killing occurs by reason or on the occasion of the robbery. The prosecution proved that the stabbing was directly linked to the robbery, as Dela Cruz killed the victim to facilitate the taking of property and to eliminate a witness. Thus, the complex crime was correctly charged and proven.

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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 Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.