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 the accused demand money from her husband before stabbing him. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering at the time of the incident. The trial court convicted the accused and sentenced him to reclusion perpetua. Hence, this appeal.

—

ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi can 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 credible and reliable. She had a clear view of the accused, and there was no evidence to suggest any ill motive on her part to falsely testify against him. The testimony was consistent and withstood rigorous cross-examination. The defense failed to impeach her credibility.

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 have been at the scene of the crime. In this case, the accused merely claimed to be in a different city, which is not geographically impossible to travel from within the time frame of the crime. Alibi cannot prevail over the positive, categorical, and consistent identification of the accused by a credible eyewitness.

—

DOCTRINE

Positive identification prevails over alibi. 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. Where there is credible eyewitness identification, alibi necessarily fails.

—

DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court of Quezon City, Branch 90, finding accused-appellant Juan Dela Cruz GUILTY beyond reasonable doubt of Robbery with Homicide and sentencing him to reclusion perpetua, is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.