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

Ponente: J. PERFECTO

FACTS

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, 2015, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and recognized him because the room was illuminated by a streetlight coming through the window. She identified the accused in court and during a police lineup.

The defense interposed the defense of alibi, claiming that at the time of the incident, the accused was in his house in a different barangay, approximately 15 kilometers away, celebrating his daughter’s birthday with family and friends. Several defense witnesses corroborated his alibi.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt, giving full credence to the eyewitness identification and rejecting the alibi. 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.

On appeal, the Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal before the Supreme Court.

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ISSUES

1. Whether the eyewitness identification of the accused was reliable and sufficient to establish his guilt beyond reasonable doubt.
2. Whether the defense of alibi should be given credence in light of the positive identification by the prosecution witness.
3. Whether the crime committed was properly qualified as Robbery with Homicide.

RULING

1. On the reliability of the eyewitness identification:
The Supreme Court found the eyewitness identification unreliable. The witness claimed recognition due to a streetlight, but the prosecution failed to establish the sufficiency of lighting and the opportunity for the witness to clearly see the perpetrator’s face. No evidence was presented regarding the brightness of the streetlight, its distance from the window, or whether obstacles obstructed the light. The witness’s identification was also uncorroborated by any physical evidence linking the accused to the crime. In criminal cases, positive identification must be credible, categorical, and consistent, and any doubt as to its reliability must be resolved in favor of the accused.

2. On the defense of alibi:
While alibi is generally a weak defense, it may be upheld when the prosecution’s evidence is weak. Here, the accused presented credible witnesses and evidence (photographs, guest list) supporting his presence elsewhere. More importantly, the prosecution failed to prove that it was physically impossible for the accused to be at the crime scene. The distance of 15 kilometers, without evidence of travel time or lack of transportation, did not rule out the possibility of his presence at the crime scene. However, given the weakness of the prosecution’s identification, the alibi assumes significance.

3. On the proper crime:
Given the reversal of the conviction, the Court did not reach this issue.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is GRANTED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan dela Cruz for Robbery with Homicide is REVERSED and SET ASIDE. Accused-appellant Juan dela Cruz is ACQUITTED on the ground of reasonable doubt. The Director of the Bureau of Corrections is ordered to immediately release accused-appellant from custody unless he is being held for another lawful cause. Let an entry of final judgment be issued immediately.

SO ORDERED.