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 commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene with a bloodied knife.

The defense 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 defense presented several family members to corroborate his alibi.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The RTC gave full credence to the eyewitness testimony of Maria Reyes, noting her positive identification and the consistency of her account. The court rejected the defense of alibi for being weak and unsubstantiated.

On appeal, the Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal before the Supreme Court.

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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 qualifying circumstance of “with homicide” was properly appreciated.

RULING

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

The Supreme Court upheld the findings of the lower courts. The eyewitness testimony of Maria Reyes was found to be clear, credible, and consistent. She had no motive to falsely testify against the accused. Her positive identification, made under well-lit conditions and without hesitation, prevails over the defense of alibi.

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

The defense of alibi is inherently weak and must be supported by clear and convincing evidence. 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 physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable within the timeframe. Positive identification by a credible witness trumps alibi.

3. The qualifying circumstance of “with homicide” was properly appreciated.

Robbery with Homicide is a special complex crime where the homicide may be either intentional or incidental. The prosecution established that the killing occurred by reason or on the occasion of the robbery. The fact that the victim was killed during the commission of the robbery satisfies the element of “with homicide” under Article 294.

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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.