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

Ponente: J. PERFECTO

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. She testified that she saw Dela Cruz enter their house, demand money, and stab her husband when he resisted. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in a different barangay attending a fiesta at the time of the incident.

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.

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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 positive identification.
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 held that the positive identification of the accused by eyewitness Maria Santos was clear, categorical, and consistent. Her testimony withstood rigorous cross-examination and was corroborated by physical evidence, including the recovery of the knife and stolen items. The Court emphasized that positive identification, when credible, is the strongest evidence of guilt.

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

The defense of alibi is inherently weak and must be supported by credible corroboration. Dela Cruz failed to prove that it was physically impossible for him to be at the crime scene. The barangay where the fiesta was held was only 30 minutes away, making it possible for him to have committed the crime. Alibi cannot stand against the positive and credible testimony of an eyewitness.

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

The use of a knife, a deadly weapon, was integral to the commission of the crime. It was used to intimidate the victim and to consummate the homicide when the victim resisted. Thus, the crime was properly qualified as Robbery with Homicide under Article 294(1) of the Revised Penal Code.

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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 and sentencing him to suffer the penalty of reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.