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, 2010, 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 was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw Dela Cruz, whom she knew personally, stab her husband and ransack their bedroom. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a fiesta 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 positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated to convict the accused of Robbery with Homicide.

RULING

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

The Court affirmed the findings of the lower courts. The testimony of eyewitness Maria Santos was found to be credible, consistent, and categorical. She positively identified Dela Cruz as the perpetrator, and her testimony was corroborated by physical evidence and the dying declaration of the victim. The defense failed to impute 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 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 fiesta was not so far as to preclude his presence at the crime scene.

3. The qualifying circumstance of homicide was properly appreciated.

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 taking of personal property was established, and the homicide was integrated with the robbery. Thus, all elements of the crime were present:
– Taking of personal property with violence or intimidation against persons;
– Property belongs to another;
– Unlawful taking with intent to gain (animus lucrandi); and
– Homicide was committed by reason or on the occasion of the robbery.

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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.