GR No. 123456, *People v. Dela Cruz* (2020)

FACTS: Juan Dela Cruz was charged with the crime of robbery with homicide. The prosecution presented evidence that Dela Cruz forcibly took the victim’s wallet and, during the struggle, stabbed the victim, causing his death. The Regional Trial Court (RTC) convicted Dela Cruz. On appeal, the Court of Appeals (CA) affirmed the RTC’s decision. Dela Cruz appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, claiming the eyewitness identification was unreliable and that he was merely present at the scene.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of Juan Dela Cruz for the crime of robbery with homicide.

RULING

No, the Court of Appeals did not err. The Supreme Court affirmed the conviction. The Court held that all elements of robbery with homicide under Article 294(1) of the Revised Penal Code were proven beyond reasonable doubt: (1) the taking of personal property with violence or intimidation against a person; (2) the property belongs to another; (3) the taking is done with animo lucrandi (intent to gain); and (4) on the occasion of the robbery, homicide is committed. The Court found the testimony of the eyewitness credible, positive, and consistent, and ruled that the defense of denial could not prevail over such positive identification. The killing was deemed an integral part of the robbery, hence the special complex crime was properly appreciated.