G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. PERFECTO

FACTS

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, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene of the crime. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family reunion 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 by an eyewitness.
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 testimony of eyewitness Maria Reyes was credible, consistent, and given in a straightforward manner. She had no motive to falsely testify against the accused. Her positive identification of Dela Cruz as the person she saw fleeing the crime scene, coupled with the corroborative physical evidence (the stolen items recovered from Dela Cruz’s possession), established his guilt beyond reasonable doubt.

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 scene of the crime. Dela Cruz’s claim of being in a different city was not substantiated by credible witnesses or documentary evidence. Moreover, the distance between the two locations was not so great as to preclude his presence at the crime scene. Thus, alibi must yield to the positive identification by the eyewitness.

3. The qualifying circumstance of homicide was properly appreciated.

Robbery with Homicide is a special complex crime where the homicide may be either intentional or incidental. The prosecution proved that the killing occurred by reason or on the occasion of the robbery. The fact that the victim was stabbed during the forcible taking of his property satisfies the elements of the crime. The trial court correctly appreciated the qualifying circumstance.

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

Costs against accused-appellant.

SO ORDERED.