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 valued at ₱50,000. 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, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. The defense presented the testimonies of Dela Cruz’s relatives to corroborate his alibi.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The RTC gave more weight to the positive identification by the eyewitness over the accused’s alibi. 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 should prevail over the positive identification by an eyewitness.
3. Whether the penalty imposed is correct.

RULING

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

The Court held that all elements of Robbery with Homicide were established:
– Taking of personal property belonging to another proven by the missing cash and jewelry.
– Unlawful taking with intent to gain inferred from the forcible entry and asportation.
– Violence or intimidation against a person the stabbing of Pedro Santos.
– Homicide as a result or on occasion of the robbery the killing occurred during the commission of the robbery.

The positive identification by eyewitness Maria Reyes was clear, consistent, and credible. She had no ill motive to falsely testify against the accused.

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

The Court reiterated the well-settled doctrine that alibi is inherently weak 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 somewhere else 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 prove physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable within the timeframe.

3. The penalty imposed is correct.

Robbery with Homicide under Article 294 is punishable by reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the penalty of reclusion perpetua was correctly imposed by the lower courts. The civil indemnity, moral damages, and exemplary damages awarded were also in accordance with prevailing jurisprudence.

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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.