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 took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and recognized him because the room was well-lit. She also testified that she heard her husband shouting for help before she saw the accused fleeing.

The defense interposed the defense of alibi, claiming that the accused was in a different city attending a family reunion at the time of the incident. The accused presented his aunt and cousin to corroborate his alibi.

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.

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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 the eyewitness.

RULING

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

The Court held that the positive identification of the accused by the eyewitness, Maria Santos, was clear, categorical, and consistent. She had a good opportunity to see the accused because the room was illuminated, and she knew him prior to the incident as a neighbor. The Court emphasized that positive identification, when credible and categorical, prevails over alibi and denial.

The elements of Robbery with Homicide were all established:
– Taking of personal property Cash and jewelry were stolen.
– With intent to gain (animus lucrandi) Inherent in the act of robbery.
– With violence or intimidation against a person The accused was armed with a knife.
– Homicide was committed The victim died from stab wounds.
– The homicide was committed by reason or on occasion of the robbery The killing occurred during the commission of the robbery.

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

The defense of 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 scene of the crime. In this case, the accused claimed to be in a different city, but the distance was not so great as to preclude his presence at the crime scene. Moreover, alibi becomes even weaker in the face of positive identification by a credible witness.

The Court also noted that there was no ill motive on the part of the eyewitness to falsely testify against the accused.

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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.