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, 2018, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing 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, presented an alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the crime. The trial court found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua.

On appeal, Dela Cruz argued that the prosecution failed to prove his guilt beyond reasonable doubt, citing inconsistencies in the eyewitness’s testimony and the weakness of the alibi.

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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.

RULING

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

The Court held that the testimony of the eyewitness, Maria Reyes, was credible and consistent. Minor inconsistencies in her testimony did not affect her overall credibility, as they pertained to trivial details and did not undermine the core of her account—that she saw Dela Cruz fleeing the crime scene with a bloodied knife. The Court emphasized that positive identification prevails over alibi, especially when the witness had no motive to falsely testify.

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

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 be at the crime scene. Dela Cruz failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable. The Court reiterated the doctrine that alibi is inherently weak and easily fabricated, and it cannot stand against the positive identification of the accused by a credible witness.

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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 of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED. Costs against accused-appellant.

SO ORDERED.