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, 2010, in Quezon City, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, and took cash and jewelry. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw Dela Cruz, whom she knew personally, stab her husband. 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 trial court gave credence to the eyewitness account, convicted Dela Cruz, and sentenced him to reclusion perpetua. Dela Cruz appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the trial court erred in convicting accused-appellant of Robbery with Homicide based on the eyewitness identification, despite his defense of alibi.

RULING

The Supreme Court AFFIRMED the conviction.

The Court held that positive identification by a credible eyewitness prevails over the defense of alibi. For alibi to prosper, the accused must prove not only that he was elsewhere 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 establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable within the timeframe.

Moreover, the Court found the testimony of Maria Santos credible, consistent, and given in a straightforward manner. There was no evidence of ill motive on her part to falsely testify against the accused. The elements of Robbery with Homicide were sufficiently established: (1) the taking of personal property with violence or intimidation; (2) the property belonged to another; (3) the taking was done with animo lucrandi; and (4) on the occasion of the robbery, homicide was committed.

The Court also noted that the trial court’s assessment of witness credibility is entitled to great respect, as it had the opportunity to observe the witnesses’ demeanor firsthand.

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DOCTRINE:

1. Positive identification by a credible witness prevails over alibi. Alibi is inherently weak and must demonstrate the physical impossibility of the accused’s presence at the crime scene.
2. Credibility of eyewitness testimony is not impaired by minor inconsistencies, especially when the witness’s account remains consistent on material points.
3. Robbery with Homicide under Article 294, Revised Penal Code is a special complex crime where homicide is committed by reason or on the occasion of the robbery. The prosecution must prove both the robbery and the killing, and that the latter was committed in connection with the former.

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Case dismissed. Costs against accused-appellant.