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, 2010, Dela Cruz, armed with a knife, entered the house 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 from Santos’s house immediately after the incident. The defense, however, presented an alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the crime. The trial court found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. Dela Cruz appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the eyewitness testimony was unreliable.

ISSUE

Whether the trial court erred in convicting accused-appellant Juan Dela Cruz of Robbery with Homicide based on the testimony of a single eyewitness, despite the defense of alibi.

RULING

NO. The Supreme Court AFFIRMED the conviction of accused-appellant Juan Dela Cruz.

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RATIONALE

1. Credibility of Eyewitness Testimony
The Court emphasized that the assessment of witness credibility is best left to the trial court, which has the opportunity to observe the witness’s demeanor, conduct, and manner of testifying. The trial court found the eyewitness, Maria Reyes, to be credible and consistent in her testimony. Her positive identification of Dela Cruz as the perpetrator was clear and unequivocal. The Court has consistently held that the testimony of a single eyewitness, if credible and positive, is sufficient to support a conviction.

2. Weakness of Alibi as a Defense
The defense of alibi is inherently weak 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 elsewhere when the crime was committed but also that it was physically impossible for him to have been 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. Moreover, alibi becomes even less credible when there is no corroboration from disinterested witnesses.

3. Elements of Robbery with Homicide
The Court found that all elements of Robbery with Homicide were present:
– The taking of personal property with intent to gain;
– The use of violence or intimidation against a person;
– The property taken belonged to another;
– The taking was accomplished with violence against or intimidation of a person; and
– On the occasion of the robbery, homicide was committed.
The prosecution proved these elements through the testimony of the eyewitness and corroborative evidence, such as the stolen items recovered from Dela Cruz’s possession.

4. Conspiracy and Intent
The Court noted that when homicide is committed as a consequence or on the occasion of a robbery, all those who took part in the robbery shall be guilty of the special complex crime of Robbery with Homicide, unless it is shown that they endeavored to prevent the killing. In this case, Dela Cruz acted alone, and his intent to gain was evident from his actions.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court convicting accused-appellant Juan Dela Cruz of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.