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, 2018, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and forcibly took cash and jewelry. During the robbery, Pedro Santos resisted, and in the ensuing struggle, the accused stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and witnessed the stabbing. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering at the time of the incident.

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 be given credence 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 eyewitness Maria Santos was clear, categorical, and consistent. She had a good opportunity to see the accused during the incident as the house was well-lit, and she was face-to-face with him during the struggle. Her testimony was corroborated by physical evidence and the medico-legal report confirming the fatal stab wound.

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

The defense of alibi is inherently weak and must be supported by credible evidence showing the physical impossibility of the accused being at the scene of the crime. In this case, the accused failed to prove that it was impossible for him to be at the crime scene. The distance between the alleged family gathering and the victim’s house was not insurmountable, and no credible witnesses were presented to firmly establish his presence elsewhere at the exact time of the crime.

3. The qualifying circumstance of homicide was properly appreciated.

For Robbery with Homicide to be convicted, it is sufficient that the homicide be committed by reason or on the occasion of the robbery. The prosecution established that the killing occurred during the commission of the robbery, as the victim resisted the unlawful taking. The intent to rob was proven by the missing cash and jewelry, and the homicide was a direct consequence of the robbery.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan dela Cruz for the crime of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.