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, 2015, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. 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 positively identified Dela Cruz as the perpetrator.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a fiesta at the time of the incident. The defense presented testimonies of friends and relatives to corroborate his alibi.

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.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant based on the positive identification by the eyewitness, despite his defense of alibi.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of accused-appellant Juan Dela Cruz.

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RATIONALE

1. Positive Identification Over Alibi
– The Court reiterated the well-established doctrine that positive identification by a credible witness prevails over the defense of alibi. Alibi is inherently weak and unreliable unless supported by clear and convincing evidence that the accused was so far away that it was physically impossible for him to have been at the crime scene.
– In this case, the eyewitness, Maria Santos, gave a clear, consistent, and categorical testimony identifying Dela Cruz as the assailant. She had sufficient opportunity to see his face during the incident, as the room was well-lit. Her testimony remained unshaken during cross-examination.
– Dela Cruz’s alibi failed to meet the requirement of physical impossibility. The distance between the crime scene and the fiesta location was only approximately 50 kilometers, which could be traversed by vehicle in about an hour. Hence, it was not impossible for him to have been at the crime scene.

2. Credibility of Witness
– The trial court’s assessment of witness credibility is accorded great respect, as it had the opportunity to observe the witness’s demeanor, sincerity, and candor. The CA correctly upheld the RTC’s findings, as no substantial reason was shown to overturn them.
– The defense failed to prove any ill motive on the part of Maria Santos to falsely testify against Dela Cruz. Absent such proof, her testimony is deemed credible.

3. Elements of Robbery with Homicide
– The Court found all elements present:
a) There was a robbery committed by means of violence or intimidation;
b) A homicide was committed as a result or on the occasion of the robbery; and
c) The homicide was perpetrated by the accused or his accomplices.
– The taking of personal property (cash and jewelry) was established, and the killing occurred during the robbery. The intent to rob was evident from the accused’s actions.

4. Penalty
– Robbery with Homicide is punishable by reclusion perpetua to death. In the absence of aggravating circumstances, the penalty of reclusion perpetua was correctly imposed by the lower courts. Civil indemnity, moral damages, and exemplary damages were also properly awarded in accordance with prevailing jurisprudence.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.