G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. PERFECTO

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 the evening of 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 reunion at the time of the incident. The trial court found the prosecution’s evidence credible and convicted Dela Cruz, sentencing him to reclusion perpetua and ordering him to pay civil indemnity, moral damages, and restitution.

Dela Cruz appealed, arguing that the trial court erred in giving credence to the lone eyewitness and in disregarding his alibi, which was corroborated by several family members.

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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.

RULING

1. On the proof of guilt beyond reasonable doubt YES.

The Court affirmed the conviction. The testimony of eyewitness Maria Reyes was found to be clear, consistent, and credible. She positively identified Dela Cruz as the perpetrator, providing details such as his clothing, approximate height, and the weapon used. Her testimony remained unshaken during cross-examination. The Court emphasized that positive identification, when categorical and consistent, prevails over alibi and denial.

Moreover, the elements of Robbery with Homicide were sufficiently established:
– Taking of personal property Cash and jewelry were stolen.
– With intent to gain The taking was unlawful.
– With violence or intimidation A knife was used.
– Homicide was committed The victim died from stab wounds.
– Homicide was a consequence of the robbery The killing occurred during the commission of the robbery.

2. On the defense of alibi NO.

The defense of alibi is inherently weak and cannot prevail over positive identification. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to be at the crime scene. Dela Cruz failed to establish physical impossibility, as the location of the family reunion was only a few hours away from Quezon City by land travel. Corroboration by relatives, who are naturally biased, does not strengthen the defense.

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DOCTRINE

– Positive identification by a credible eyewitness prevails over the defense of alibi and denial. Alibi is inherently weak and must demonstrate the physical impossibility of the accused’s presence at the crime scene.
– In Robbery with Homicide, the prosecution must prove the elements of robbery and that the killing was committed by reason or on occasion of the robbery. The intent to rob must precede or coexist with the homicide.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court convicting accused-appellant Juan Dela Cruz of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED. He is ordered to pay the heirs of Pedro Santos ₱100,000 as civil indemnity, ₱100,000 as moral damages, ₱100,000 as exemplary damages, and ₱50,000 as restitution, with legal interest at 6% per annum from finality until fully paid.

SO ORDERED.