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, 2015, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the robbery, Santos was stabbed multiple times, resulting in his death. Several pieces of jewelry and cash were taken.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who claimed to have seen Dela Cruz fleeing the scene. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal.

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ISSUES
1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi can prevail over the positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated.

RULING

1. On the proof of guilt beyond reasonable doubt YES.

The Court held that the prosecution successfully established the guilt of the accused. The eyewitness, Maria Reyes, gave a clear, consistent, and credible account of the incident. She positively identified Dela Cruz as the person she saw fleeing from the victim’s house immediately after hearing shouts for help. Her testimony was corroborated by physical evidence and the dying declaration of the victim, who identified his assailant before succumbing to his injuries.

2. On the defense of alibi NO.

The defense of alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness. 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. Dela Cruz failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable within the timeframe of the incident.

3. On the qualifying circumstance of homicide YES.

Robbery with Homicide is a special complex crime where the homicide may be either intentional or incidental. The prosecution proved that the killing occurred by reason or on the occasion of the robbery. The number and severity of the stab wounds indicated intent to kill, which qualified the crime under Article 294(1) of the Revised Penal Code.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz for the crime of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.