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, in Quezon City, Dela Cruz, armed with a knife, entered the residence 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 recognized as a former neighbor, inside their house holding a knife and standing over her husband’s body. She also testified that she saw Dela Cruz take a jewelry box before fleeing.

The defense interposed alibi and denial. Dela Cruz claimed he was in another city attending a fiesta during the incident. He presented a friend who corroborated his presence at the fiesta.

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.

—

ISSUES:

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi and denial should prevail over the positive identification by the 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 positive identification by eyewitness Maria Santos was clear, consistent, and credible. She had known Dela Cruz for years as a former neighbor, and there was no ill motive for her to falsely testify against him. Her testimony on the material events—seeing Dela Cruz inside their house, holding a knife, standing over her husband’s body, and taking the jewelry box—was detailed and remained unshaken on cross-examination.

2. The defense of alibi and denial cannot prevail over positive identification.

The Court reiterated the well-established doctrine that alibi is the weakest defense and must be supported by clear and convincing evidence of physical impossibility for the accused to be at the scene of the crime. Dela Cruz failed to prove that it was physically impossible for him to travel from the fiesta to the crime scene, which was only a few hours away by public transportation. Denial, like alibi, is inherently weak and cannot prevail over the positive testimony of a credible witness.

3. The qualifying circumstance of homicide was properly appreciated.

Robbery with Homicide is a special complex crime where the homicide may be committed by reason or on occasion of the robbery. It is not necessary that the homicide be intended; it is enough that the killing is connected to the robbery. The prosecution established that the killing occurred during the commission of the robbery, as the stabbing happened when the victim resisted the unlawful taking. Thus, the crime was correctly classified as Robbery with Homicide.

—

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 and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.