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, Dela Cruz stabbed Santos, causing his death, and took cash and jewelry amounting to ₱50,000.00.

The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene of the crime. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city at the time of the incident. The trial court convicted Dela Cruz, sentencing him to reclusion perpetua and ordering 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 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 first issue: YES, 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. She positively identified Dela Cruz as the perpetrator, and her testimony was corroborated by physical evidence and the dying declaration of the victim. The Court emphasized that positive identification prevails over alibi, especially when the eyewitness had no motive to falsely testify against the accused.

2. On the second issue: NO, the defense of alibi cannot prevail over positive identification.

The defense of alibi is inherently weak and must be supported by clear and convincing evidence. Dela Cruz failed to prove that it was physically impossible for him to be at the crime scene at the time of the incident. The Court reiterated the doctrine that alibi is unavailing when the accused is positively identified by a credible witness.

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DOCTRINE

The defense of alibi cannot prevail over the positive identification of the accused by a credible eyewitness, especially when the accused fails to prove that it was physically impossible for him to be at the scene of the crime at the time of its commission.

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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 with MODIFICATION. Accused-appellant is ordered to pay the heirs of the victim:

1. Civil indemnity ₱75,000.00;
2. Moral damages ₱75,000.00;
3. Exemplary damages ₱75,000.00; and
4. Interest at 6% per annum on all damages from the finality of this decision until fully paid.

SO ORDERED.