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 evidence established that during the commission of a robbery inside a convenience store, a security guard intervened. In the ensuing struggle, the accused shot and killed the guard. The accused interposed the defense of denial and alibi, claiming he was in a different city at the time of the incident. The Regional Trial Court convicted the accused, finding the positive identification by an eyewitness credible and the defense weak. On appeal, the accused argued that the prosecution failed to prove his guilt beyond reasonable doubt, emphasizing inconsistencies in the eyewitness’s testimony regarding the lighting conditions at the scene.

ISSUE

Whether or not the conviction of the accused for the crime of Robbery with Homicide should be upheld, considering the alleged inconsistencies in the prosecution’s evidence.

RULING

YES, the conviction is affirmed. The Court found no merit in the appeal. The alleged inconsistencies in the eyewitness’s testimony pertained to minor and trivial details (the exact wattage of a light bulb) and did not relate to the core fact of witnessing the accused shoot the victim. Such minor inconsistencies may even enhance the witness’s credibility, as they negate the suspicion of a rehearsed testimony. The positive identification by the eyewitness, who had a clear view of the accused, prevails over the weak defenses of denial and alibi, which are inherently unreliable. All elements of Robbery with Homicide under Article 294(1) of the Revised Penal Code were sufficiently proven: (1) the taking of personal property with intent to gain; (2) the taking was with violence or intimidation against persons; (3) the property belonged to another; (4) the taking was unlawful; and (5) by reason or on occasion of the robbery, homicide was committed. The trial court’s assessment of witness credibility is entitled to great weight and respect. Thus, the guilt of the accused was proven beyond reasonable doubt.