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, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene with a bloodied knife.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. Several relatives testified to corroborate his alibi.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt, giving full credence to the eyewitness testimony and rejecting the alibi defense. The RTC sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim. The Court of Appeals (CA) affirmed the RTC decision in toto.

Dela Cruz appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the lower courts erred in disregarding his 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 over the positive identification by an eyewitness.

RULING

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

The Supreme Court held that the positive identification by eyewitness Maria Reyes, who had no ill motive to falsely testify, was credible and sufficient to establish Dela Cruz’s presence and participation in the crime. Her testimony was clear, consistent, and corroborated by physical evidence (the bloodied knife recovered near the scene, which bore Dela Cruz’s fingerprints). The Court emphasized that positive identification prevails over alibi, especially when the alibi is not physically impossible.

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

The defense of alibi requires proof that the accused was at another place at the time of the commission of the offense and that it was physically impossible for him to have been at the crime scene. Here, Dela Cruz’s claimed location was only a few hours away by vehicle, making it not physically impossible for him to have committed the crime and returned. Alibi is inherently weak and easily fabricated; thus, it cannot overcome the positive testimony of a credible eyewitness.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan Dela Cruz for 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:

– Civil indemnity: ₱100,000.00
– Moral damages: ₱100,000.00
– Exemplary damages: ₱100,000.00
– Actual damages: ₱50,000.00 (duly substantiated)
– Interest at 6% per annum on all damages from finality of judgment until fully paid.

SO ORDERED.