G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. PERFECTO

FACTS

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, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and forcibly took cash and jewelry. During the robbery, Pedro Santos resisted, and in the ensuing struggle, the accused stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused enter their house, demand money, and stab her husband when he refused to comply. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering at the time of the incident. The accused also denied owning the knife presented as evidence.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua. 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 can prevail over the positive identification by an eyewitness.
3. Whether the aggravating circumstance of dwelling was correctly appreciated.

RULING

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

The Supreme Court held that the positive identification of the accused by eyewitness Maria Santos was clear, categorical, and consistent. She had no ill motive to falsely testify against the accused. Her testimony was corroborated by physical evidence and the dying declaration of the victim, who identified the accused as his assailant before succumbing to his injuries. The defense failed to cast any reasonable doubt on her credibility.

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

The Court reiterated the well-established doctrine that alibi is the weakest defense 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. The accused failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable within the timeframe.

3. The aggravating circumstance of dwelling was correctly appreciated.

The crime was committed in the victim’s own house, which is the essence of the aggravating circumstance of dwelling under Article 14 of the Revised Penal Code. The accused deliberately entered the victim’s residence to commit robbery, and the homicide ensued therefrom. The Court affirmed that dwelling was properly considered, warranting the imposition of the maximum penalty.

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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 the crime of Robbery with Homicide is AFFIRMED. Costs against accused-appellant.

SO ORDERED.