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, 2010, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the commission of the robbery, Dela Cruz stabbed Santos, causing his death. 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. 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 prosecution successfully established all the elements of Robbery with Homicide: (a) the taking of personal property with intent to gain; (b) with violence or intimidation against a person; (c) the property taken belongs to another; and (d) on the occasion of the robbery, homicide was committed.

The testimony of eyewitness Maria Santos was found to be credible, consistent, and categorical. She had a clear view of the accused during the incident, and her identification was not tainted by any ill motive. The Court emphasized that positive identification, when credible and categorical, prevails over alibi and denial.

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

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 failed to establish physical impossibility. The place where he claimed to be was not so far as to preclude his presence at the crime scene. Hence, his alibi must fail.

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 cause his death. Thus, the qualifying circumstance was correctly appreciated, warranting the penalty of reclusion perpetua under Article 294 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 conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.