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 commission of the robbery, Dela Cruz stabbed Santos, causing his death. The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene with a bag containing stolen items.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. The defense presented several family members to corroborate his alibi.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The RTC gave more credence to the positive identification by the eyewitness over the defense of alibi. 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 an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated in the crime of robbery.

RULING

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

The Court held that the prosecution successfully established all the elements of Robbery with Homicide:
– Taking of personal property belonging to another;
– With intent to gain (animus lucrandi);
– With violence or intimidation against persons;
– Homicide was committed on the occasion or by reason of the robbery.

The eyewitness, Maria Reyes, gave a clear, consistent, and credible account of the incident. Her positive identification of Dela Cruz as the perpetrator was categorical and unwavering. The Court emphasized that positive identification prevails over alibi, especially when the witness had no ill motive to falsely testify.

2. 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 that the accused was so far away that it was physically impossible for him to be at the scene of the crime. In this case, Dela Cruz claimed to be in a different city, but the distance was not so great as to preclude his presence at the crime scene. Moreover, alibi becomes even less credible when, as here, there is positive identification by a credible witness.

3. The qualifying circumstance of homicide was properly appreciated.

The killing was committed by reason or on the occasion of the robbery. The evidence showed that the homicide was directly linked to the robbery, as the victim was killed to facilitate the taking of his property or to eliminate a witness. Thus, the crime was properly classified as Robbery with Homicide under Article 294(1) 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 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.