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, 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 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 should prevail over the positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated in the crime of robbery.

RULING

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

The Court held that the positive identification by eyewitness Maria Reyes was credible, consistent, and categorical. She had a clear view of the accused during the incident and had no motive to falsely testify. The defense failed to impeach her credibility. The testimony of a single eyewitness, if credible and positive, is sufficient to support a conviction.

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

Alibi is inherently weak 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 crime scene. Dela Cruz failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable. Positive identification trumps alibi.

3. The qualifying circumstance of homicide was properly appreciated.

Robbery with Homicide is a special complex crime where the homicide may be committed by reason or on occasion of the robbery. It is not necessary that the homicide be intended; it is enough that the killing and the robbery are intimately connected. The prosecution established that the killing occurred during the commission of the robbery, as the stabbing happened when the victim resisted 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.