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

Ponente: J. Reyes

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, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the commission of the robbery, Dela Cruz stabbed Santos, causing his death. The prosecution presented eyewitness testimony from Maria Santos, the victim’s wife, who identified Dela Cruz as the perpetrator. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in a different city at the time of the incident.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Dela Cruz appealed to the Supreme Court via a petition for review on certiorari, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the defense of alibi should have been given credence.

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ISSUES
1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi can prevail over positive identification by an eyewitness.

RULING

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

The Supreme Court held that the prosecution successfully established the guilt of Dela Cruz beyond reasonable doubt. The eyewitness, Maria Santos, gave a clear, consistent, and credible account of the incident. She testified that she saw Dela Cruz enter their house, demand money, and stab her husband when he resisted. Her testimony was corroborated by physical evidence and the medico-legal report confirming the cause of death. The Court emphasized that positive identification, when categorical and consistent, prevails over denial and alibi.

2. On the defense of alibi NO.

The defense of alibi cannot prosper in light of the positive identification by the eyewitness. For alibi to be credible, 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. Dela Cruz failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable. Moreover, alibi is inherently weak and easily fabricated, and it must yield to positive identification.

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DOCTRINE

– Positive identification by a credible eyewitness prevails over the defense of alibi and denial.
– For alibi to be credible, the accused must prove: (a) presence in another place at the time of the commission of the offense, and (b) physical impossibility to be at the crime scene.
– The defense of alibi is inherently weak and cannot stand against the positive testimony of a credible witness.

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DISPOSITIVE PORTION

WHEREFORE, the petition is DENIED. The Decision of the Court of Appeals affirming the conviction of Juan Dela Cruz for Robbery with Homicide is AFFIRMED. Costs against accused-appellant.

SO ORDERED.