G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. PERFECTO

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, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos.

The prosecution presented eyewitness Maria Reyes, a neighbor who testified that she saw Dela Cruz forcibly enter Santos’ house and later flee carrying a bag. She also heard Santos shouting for help before he was found dead. The police recovered a bloodied knife at the scene, which was later identified through fingerprint analysis as bearing Dela Cruz’s prints.

The defense interposed the defense of alibi, claiming that Dela Cruz was at a family gathering in a different town at the time of the incident. He denied any involvement in the crime and asserted that he was falsely implicated due to a prior land dispute with the victim’s family.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua without eligibility for parole. 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 should be given credence over the positive identification by an eyewitness.
3. Whether the aggravating circumstance of dwelling was properly appreciated.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.

The Court held that the prosecution successfully established all elements of Robbery with Homicide: (a) the taking of personal property with intent to gain; (b) with violence or intimidation against a person; (c) the property taken belongs to another; (d) the taking is characterized by intent to gain; and (e) on the occasion of the robbery, homicide was committed.

The positive identification by eyewitness Maria Reyes, who had no motive to falsely testify, was clear, consistent, and credible. Her testimony was corroborated by physical evidence, particularly the knife with Dela Cruz’s fingerprints found at the crime scene. The defense failed to impute any ill motive on the part of Reyes that would undermine her credibility.

2. The defense of alibi cannot prevail over positive identification.

The Court reiterated the well-settled doctrine that 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 location of the family gathering was only an hour away from the crime scene by available transportation.

3. The aggravating circumstance of dwelling was correctly appreciated.

The crime was committed inside the victim’s house, which constitutes the aggravating circumstance of dwelling under Article 14 of the Revised Penal Code. The prosecution proved that the accused deliberately entered the victim’s residence to commit the robbery, and the homicide ensued therein. This aggravating circumstance was properly considered in imposing the penalty.

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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 without eligibility for parole is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.