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, 2015, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw Dela Cruz, whom she recognized as a former neighbor, fleeing their house immediately after hearing her husband’s shouts. She also identified the stolen items recovered from Dela Cruz’s possession upon his arrest.

The defense interposed alibi and denial. Dela Cruz claimed he was in a different city attending a fiesta at the time of the incident, supported by the testimonies of two friends. He also argued that the identification by Maria Santos was unreliable due to poor lighting and her emotional state.

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.

—

ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi and denial can prevail over positive identification.
3. Whether the qualifying circumstance of homicide was properly appreciated.

RULING

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

The Court affirmed the findings of the lower courts. The positive identification by eyewitness Maria Santos, who knew Dela Cruz prior to the incident, was clear, consistent, and credible. Her testimony on seeing Dela Cruz flee the crime scene and her identification of the stolen items were corroborated by physical evidence. The defense failed to show any ill motive on her part to falsely testify.

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

Alibi is inherently weak and must be supported by clear and convincing evidence that the accused was so far away that it was physically impossible for him to be at the crime scene. Dela Cruz’s claim of being in a different city was not physically impossible, as the distance could be traversed in a few hours. Denial, like alibi, is an intrinsically weak defense and cannot stand against positive identification.

3. The qualifying circumstance of 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 Dela Cruz was armed with a knife and used it when the victim resisted proved that the homicide was integral to the commission of the robbery.

—

DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the Regional Trial Court’s judgment finding accused-appellant JUAN DELA CRUZ guilty beyond reasonable doubt of the crime of Robbery with Homicide and sentencing him to suffer the penalty of reclusion perpetua is AFFIRMED.

Costs against accused-appellant.

SO ORDERED.