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, however, interposed the defense of alibi, claiming that Dela Cruz was in Bulacan at the time of the incident, attending a family gathering. The defense presented three witnesses to corroborate his alibi.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The RTC gave more credence to the positive identification by the eyewitness over the defense of alibi. 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 defense of alibi should prevail over the positive identification by the eyewitness.
2. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.

RULING

1. NO, the defense of alibi cannot prevail over the positive identification by the eyewitness.

The Supreme Court reiterated the well-established 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 scene of the crime.

In this case, Dela Cruz claimed he was in Bulacan, which is merely a few hours away from Quezon City. The Court found that it was not physically impossible for him to have traveled to Quezon City, committed the crime, and returned to Bulacan within the timeframe. Moreover, the defense witnesses were all relatives of Dela Cruz, whose testimonies were deemed biased and insufficient to establish a credible alibi.

On the other hand, Maria Santos gave a clear, consistent, and categorical testimony. She had known Dela Cruz for years, as he was a neighbor, and she had no ill motive to falsely testify against him. Her positive identification was straightforward and remained unshaken during cross-examination.

2. YES, the prosecution proved the guilt of the accused beyond reasonable doubt.

The elements of Robbery with Homicide are: (a) the taking of personal property with intent to gain; (b) with violence or intimidation against a person; (c) the property taken belongs to another; and (d) on the occasion of the robbery, homicide is committed.

All elements were proven beyond reasonable doubt:
– Maria Santos testified that she saw Dela Cruz take cash and jewelry from their bedroom.
– The taking was accomplished with violence, as Dela Cruz stabbed Pedro Santos when he resisted.
– The stolen items belonged to the Santos spouses.
– The homicide (killing of Pedro Santos) was committed on the occasion of the robbery, as the stabbing occurred while Dela Cruz was fleeing after the robbery.

The Court found the testimony of Maria Santos credible and sufficient to establish all elements of the crime. The medical certificate and the stolen items recovered from Dela Cruz’s possession further corroborated her testimony.

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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 is AFFIRMED. Costs against accused-appellant.

SO ORDERED.