GR No. 123456, *People v. Dela Cruz* (January 15, 2023)

FACTS:
Accused-appellant Juan Dela Cruz was charged with the crime of Robbery with Homicide. The prosecution evidence established that on the evening of June 10, 2018, Dela Cruz entered a convenience store, declared a hold-up, and shot the store cashier, resulting in the latter’s death, before taking cash from the register. The defense interposed the affirmative defense of alibi, claiming Dela Cruz was in a different city at the time of the incident. The Regional Trial Court convicted Dela Cruz, finding the positive identification by an eyewitness and corroborating CCTV footage to be credible and conclusive. The Court of Appeals affirmed the conviction. Dela Cruz appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that his alibi should have been given weight.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for the crime of Robbery with Homicide.

RULING

No. The Supreme Court DENIED the appeal and AFFIRMED the conviction of accused-appellant Juan Dela Cruz for the crime of Robbery with Homicide under Article 294(1) of the Revised Penal Code.

The Court held that all the elements of Robbery with Homicide were proven beyond reasonable doubt: (1) the taking of personal property with intent to gain, (2) with violence against or intimidation of any person, and (3) the killing was committed by reason or on the occasion of the robbery. The positive identification of the accused by a credible eyewitness who had a clear view of the incident, corroborated by unambiguous CCTV footage, prevails over the weak defense of alibi. Alibi is inherently weak and must be supported by clear and convincing evidence of the physical impossibility of the accused’s presence at the crime scene, which the defense failed to establish. The findings of fact of the trial court, affirmed by the Court of Appeals, are entitled to great weight and respect, as no substantial reason was shown to overturn them. The penalty of *reclusion perpetua* without eligibility for parole was correctly imposed, and the award of damages to the heirs of the victim was modified in accordance with prevailing jurisprudence.