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 well-lit. She also testified that she heard the accused demand money from her husband before stabbing him.

The defense interposed the defense of alibi, claiming that the accused was in a different city attending a family reunion at the time of the incident. The accused presented his aunt and a cousin to corroborate his alibi.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua. 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 the eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated to convict the accused of Robbery with Homicide.

RULING

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

The Court held that the positive identification of the accused by the eyewitness, Maria Santos, was clear, categorical, and consistent. She had a good opportunity to see the accused because the room was illuminated, and she was familiar with him as they were neighbors. The defense failed to show any ill motive on her part to falsely testify against the accused.

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

The defense of 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 scene of the crime. The accused failed to establish physical impossibility, as the place where he claimed to be was only a few hours away by vehicle.

3. The qualifying circumstance of homicide was properly appreciated.

The Court found that the killing was perpetrated by reason or on the occasion of the robbery. The taking of personal property was proven, and the homicide was committed to facilitate the robbery or as a consequence thereof. Thus, the crime committed is Robbery with Homicide, a special complex crime under Article 294 of the Revised Penal Code.

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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. Costs against accused-appellant.

SO ORDERED.