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, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the robbery, Santos resisted, and Dela Cruz stabbed him multiple times, causing his death. Dela Cruz then took Santos’s wallet containing ₱5,000.00 and fled.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz enter Santos’s house and later emerge with a bloodied knife and a wallet. The police recovered the knife and wallet in Dela Cruz’s possession upon arrest. The defense interposed alibi, claiming Dela Cruz was in a different city at the time of the crime, and denied ownership of the knife and wallet.

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. Dela Cruz appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the eyewitness testimony was unreliable.

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ISSUES
1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the eyewitness testimony is credible and sufficient to sustain a conviction.
3. Whether the defense of alibi should be given credence.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.
The Supreme Court held that all elements of Robbery with Homicide were established:
– Taking of personal property Dela Cruz took Santos’s wallet.
– With intent to gain The taking was done to appropriate the money.
– With violence or intimidation Dela Cruz used a knife to subdue Santos.
– Homicide committed on the occasion of the robbery Santos’s death resulted directly from the robbery.

The recovery of the stolen wallet and the bloodied knife from Dela Cruz, corroborated by eyewitness testimony, constituted proof beyond reasonable doubt.

2. The eyewitness testimony is credible and sufficient.
The Court found no ill motive for the eyewitness, Maria Reyes, to falsely testify against Dela Cruz. Her testimony was clear, consistent, and remained unshaken during cross-examination. The trial court’s assessment of witness credibility is entitled to great weight, as it had the opportunity to observe the witness’s demeanor.

3. The defense of alibi is weak and cannot prevail over positive identification.
Alibi is inherently weak and must be supported by clear and convincing evidence. Dela Cruz failed to prove that it was physically impossible for him to be at the crime scene. Positive identification by a credible witness trumps alibi.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is AFFIRMED. Costs against accused-appellant.

SO ORDERED.