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, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Santos was stabbed, resulting in 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 Dela Cruz was in a different city attending a family reunion at the time of the crime. The trial court found the prosecution’s evidence credible and convicted Dela Cruz, sentencing him to reclusion perpetua and ordering him to pay damages.

Dela Cruz appealed, arguing that the trial court erred in giving credence to the lone eyewitness and in disregarding his alibi.

—

ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should prevail over the positive identification by an eyewitness.

RULING

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

The Court affirmed the conviction. The positive identification by eyewitness Maria Reyes was clear, consistent, and credible. She had a direct view of the incident and had known Dela Cruz prior to the crime, making her identification reliable. The defense failed to show any ill motive on her part to falsely testify.

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

The Court reiterated the well-established doctrine that alibi is the weakest defense and easily fabricated. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime was committed but also that it was physically impossible for him to be at the scene of the crime. Dela Cruz failed to establish such physical impossibility, as the location of his alibi was not so far as to preclude his presence at the crime scene.

—

DOCTRINE

Alibi vs. Positive Identification: Alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness who had no motive to testify falsely. For alibi to be a successful defense, the accused must demonstrate by clear and convincing evidence that it was physically impossible for him to have been at the locus criminis at the time of its commission.

—

DISPOSITIVE PORTION:

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court, Branch 90, Quezon City, finding accused-appellant Juan Dela Cruz GUILTY beyond reasonable doubt of Robbery with Homicide and sentencing him to reclusion perpetua, is AFFIRMED in toto.

SO ORDERED.