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, and took cash and jewelry. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene of the crime. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in a different city 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.

Dela Cruz now appeals before the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the defense of alibi should have been given credence.

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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 prevail over the positive identification by the eyewitness.

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 Cash and jewelry were stolen from the victim’s house.
– With intent to gain The taking was clearly for the purpose of gain.
– With violence or intimidation against a person The accused used a knife to threaten and eventually kill the victim.
– Homicide was committed The victim died as a direct result of the stab wounds inflicted during the robbery.

The testimony of eyewitness Maria Reyes was found to be credible, consistent, and categorical. She positively identified Dela Cruz as the perpetrator, and her testimony remained unshaken during cross-examination. The Court emphasized that positive identification prevails over alibi, especially when the witness had no ill motive to falsely testify.

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

The defense of alibi requires not only that the accused 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 prove physical impossibility. The place where he claimed to be was only a few hours away from the crime scene, and no convincing evidence was presented to show he could not have been present at the locus criminis.

Moreover, alibi is inherently weak and easily fabricated. It cannot stand against the positive, straightforward, and credible testimony of an eyewitness.

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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.