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 Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family reunion at the time of the incident. The trial court found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua without eligibility for parole, and ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim.

Dela Cruz appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the trial court erred in giving credence to the testimony of the lone eyewitness.

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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 be given credence over the positive identification by an eyewitness.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Court ruled in the affirmative. The prosecution successfully established all the elements of Robbery with Homicide:
– Taking of personal property belonging to another;
– With intent to gain (animus lucrandi);
– With violence or intimidation against persons; and
– Homicide was committed by reason or on occasion of the robbery.

The positive identification by eyewitness Maria Reyes, who had no motive to falsely testify, was clear, consistent, and credible. Her testimony was corroborated by physical evidence, including the recovery of the stolen items in the accused’s possession and the medico-legal report confirming the fatal stab wounds.

2. On the defense of alibi.

The Court ruled that the defense of alibi must fail. Jurisprudence consistently holds that alibi is a weak defense and cannot prevail over the positive identification of the accused by a credible witness. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime was committed but also that it was physically impossible for him to have been at the crime scene. Dela Cruz failed to establish physical impossibility, as the location of the family reunion was not so far as to preclude his presence at the crime scene.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court finding accused-appellant JUAN DELA CRUZ guilty beyond reasonable doubt of the crime of Robbery with Homicide is AFFIRMED with MODIFICATION. Accused-appellant is sentenced to reclusion perpetua without eligibility for parole and ordered to pay the heirs of Pedro Santos the following amounts:
– ₱100,000.00 as civil indemnity;
– ₱100,000.00 as moral damages;
– ₱100,000.00 as exemplary damages; and
– ₱50,000.00 as temperate damages.

All monetary awards shall earn interest at the rate of six percent (6%) per annum from the finality of this Decision until fully paid.

SO ORDERED.