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

Ponente: J. PERFECTO

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 Reyes, with intent to rob. During the commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Reyes.

The prosecution presented eyewitness testimony from Maria Santos, a neighbor who claimed to have seen Dela Cruz fleeing the scene. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. The defense presented several family members to corroborate his alibi.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt, giving more weight to the positive identification by the eyewitness over the defense of alibi. The RTC sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim. The Court of Appeals (CA) affirmed the RTC decision in toto.

Dela Cruz now appeals before the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the lower courts erred in disregarding his defense of alibi.

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ISSUES
1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should be given credence over the positive identification by an eyewitness.

RULING

1. On the proof of guilt beyond reasonable doubt YES.

The Supreme Court held that the prosecution successfully established all the elements of Robbery with Homicide:

– Taking of personal property The prosecution proved that cash and jewelry were taken from the victim’s house.
– With intent to gain The unlawful taking itself implies intent to gain.
– With violence or intimidation against persons The use of a knife and the killing of the victim constituted violence.
– Homicide was committed The victim’s death was established by medical evidence and testimony.

The Court emphasized that the positive identification by eyewitness Maria Santos was clear, categorical, and consistent. She had no ill motive to falsely testify against the accused. Her testimony was also corroborated by physical evidence and the sequence of events.

2. On the defense of alibi NO.

The defense of 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 failed to prove the physical impossibility of his presence at the crime scene. The distance between the location of the family gathering and the victim’s house was only approximately 50 kilometers, which could be traversed by vehicle in about an hour. Hence, it was not impossible for him to have committed the crime and returned.

Moreover, the defense witnesses were all close relatives of the accused, whose testimonies are naturally suspect due to possible bias.

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DOCTRINE

– Positive identification prevails over alibi. When there is a clear and positive identification of the accused by a credible eyewitness, the defense of alibi must fail, especially when the accused fails to prove the physical impossibility of his presence at the crime scene.
– Elements of Robbery with Homicide. The prosecution must prove: (a) the taking of personal property with intent to gain; (b) the taking was accomplished with violence or intimidation against persons; and (c) on the occasion of the robbery, homicide was committed.

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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 is AFFIRMED with MODIFICATION. Accused-appellant is sentenced to suffer the penalty of reclusion perpetua without eligibility for parole, and is ordered to pay the heirs of Pedro Reyes the following amounts:

– Civil indemnity: ₱100,000.00
– Moral damages: ₱100,000.00
– Exemplary damages: ₱100,000.00
– Actual damages: ₱50,000.00 (as proven by receipts)
– Interest at 6% per annum on all damages from finality of judgment until fully paid.

SO ORDERED.