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 Santos, the victim’s wife, who testified that she saw the accused inside their house and recognized him because the room was well-lit. She also testified that she heard the accused demand money from her husband before stabbing him. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering at the time of the incident. The trial court convicted the accused and sentenced him to reclusion perpetua. 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 the positive identification by the eyewitness.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.

The Court held that the positive identification of the accused by the eyewitness, Maria Santos, was credible and sufficient to establish his guilt. The witness had a clear view of the accused, and there was no evidence of any ill motive to falsely testify against him. The testimony was consistent and corroborated by physical evidence.

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

The defense of alibi is inherently weak and cannot stand against the positive identification of the accused by a credible witness. 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. In this case, the accused failed to prove physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable.

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DOCTRINE

The defense of alibi is inherently weak and must be rejected when the accused is positively identified by a credible witness, unless the accused demonstrates that it was physically impossible for him to be at the crime scene at the time of its commission.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court, Branch 90, Quezon City, finding accused-appellant Juan Dela Cruz GUILTY of Robbery with Homicide and sentencing him to reclusion perpetua, is AFFIRMED in toto.

SO ORDERED.