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 commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented eyewitness testimony from Maria Santos, the victim’s wife, who positively identified Dela Cruz as the perpetrator. 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 without eligibility for parole. The RTC gave full credence to the eyewitness identification and rejected the alibi defense for being weak and uncorroborated. 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 should be given credence.
3. Whether the qualifying circumstance of use of a deadly weapon was properly appreciated.

RULING

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

The Court upheld the findings of the lower courts. The positive identification by eyewitness Maria Santos, who had a clear view of the perpetrator during the well-lit incident and without any ill motive to falsely testify, prevails over the denial and alibi of the accused. The testimony was consistent, credible, and corroborated by physical evidence. The defense failed to show any reason why the witness would falsely accuse Dela Cruz.

2. The defense of alibi must fail.

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. Dela Cruz claimed he was in a neighboring city, which was only two hours away by travel. The Court ruled that this distance did not make it physically impossible for him to be at the crime scene. His alibi, unsupported by credible corroboration, is inherently weak and cannot overcome positive identification.

3. The qualifying circumstance of use of a deadly weapon was correctly appreciated.

The crime of Robbery with Homicide is a composite, special complex crime. The use of a knife, a deadly weapon, is inherent in the commission of the crime as charged and proven. The killing occurred by reason or on the occasion of the robbery. Therefore, the trial court correctly qualified the offense and imposed the penalty of reclusion perpetua without parole, pursuant to prevailing jurisprudence and Republic Act No. 9346.

—

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 without eligibility for parole is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.