GR No. 123456, January 30, 2024
People of the Philippines v. Juan Dela Cruz

FACTS

The accused, Juan Dela Cruz, was charged with the crime of Robbery with Homicide. The prosecution presented evidence that Dela Cruz entered the victim’s home, took valuable items, and, in the course thereof, stabbed the victim who later died. The defense interposed the claim of alibi, asserting that Dela Cruz was in a different city at the time of the incident. The Regional Trial Court (RTC) convicted Dela Cruz, giving full credence to the positive identification by an eyewitness. The Court of Appeals affirmed the conviction. Dela Cruz now appeals before the Supreme Court, arguing that the lower courts erred in disregarding his alibi and in relying on the testimony of a single eyewitness.

ISSUE

Whether the conviction of the accused for Robbery with Homicide, based primarily on positive eyewitness identification, should be upheld despite his defense of alibi.

RULING

NO, the appeal is DENIED. The conviction is AFFIRMED.

The Supreme Court held that the defense of alibi is inherently weak and cannot prevail over the positive and categorical identification of the accused by a credible eyewitness who had no ill motive to testify falsely. The Court reiterated the well-established doctrine that 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 demonstrate such physical impossibility, as the city where he claimed to be was merely a few hours away by vehicle. Conversely, the eyewitness testimony was found to be clear, consistent, and convincing. The Court further ruled that the crime of Robbery with Homicide is a special complex crime, and the prosecution successfully proved all its elements: the taking of personal property with intent to gain, with violence or intimidation against a person, and the killing was committed by reason or on the occasion of the robbery. Therefore, the findings of the lower courts are sustained.