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, 2018, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, presented an alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. The trial court found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. Dela Cruz appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that his alibi was not properly considered.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should be given credence in light of the positive identification by the eyewitness.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.
The Court affirmed the trial court’s findings. The eyewitness, Maria Reyes, gave a clear, consistent, and credible account of the incident. She positively identified Dela Cruz as the perpetrator, and her testimony was corroborated by physical evidence, including the recovery of the bloodied knife with Dela Cruz’s fingerprints. The defense failed to show any ill motive on the part of the witness to falsely testify against the accused.

2. The defense of alibi cannot prevail over positive identification.
The Court reiterated the well-established doctrine that alibi is the weakest defense and must be supported by clear and convincing evidence. For alibi to succeed, the accused must prove not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to be at the scene of the crime. Dela Cruz failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable. Positive identification by a credible witness prevails over alibi.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court finding accused-appellant Juan Dela Cruz GUILTY of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED. Costs against accused-appellant.

SO ORDERED.