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

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, presented an alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the crime. The trial court found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua.

On appeal, Dela Cruz argued that the prosecution failed to prove his guilt beyond reasonable doubt, citing inconsistencies in the eyewitness’s testimony and the weakness of the evidence linking him to the crime.

ISSUE

Whether the trial court erred in convicting accused-appellant of Robbery with Homicide despite alleged inconsistencies in the prosecution’s evidence and the defense of alibi.

RULING

The Supreme Court AFFIRMED the conviction.

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RATIONALE

1. Credibility of Eyewitness Testimony
The Court held that minor inconsistencies in the testimony of Maria Reyes did not impair her credibility. Inconsistencies on trivial matters may even strengthen credibility, as they indicate that the witness was not rehearsed. Reyes positively identified Dela Cruz as the perpetrator, and her testimony remained consistent on material points—the identity of the accused, the weapon used, and the sequence of events.

2. Alibi as a Defense
The defense of alibi is inherently weak and must be supported by clear and convincing evidence. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to be at the crime scene. Dela Cruz failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable within the timeframe of the crime.

3. Elements of Robbery with Homicide
The Court found all elements present:
– Robbery was committed by taking personal property with intent to gain.
– Homicide was committed on the occasion of the robbery.
– The killing was proven to be a consequence of the robbery, as the victim resisted the unlawful taking.

4. Moral Certainty of Guilt
The totality of evidence—eyewitness identification, the recovery of stolen items from Dela Cruz’s possession, and the weakness of the alibi—established moral certainty of guilt beyond reasonable doubt. The trial court’s assessment of witness credibility is entitled to great respect, absent any showing of arbitrariness.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court finding accused-appellant Juan Dela Cruz GUILTY of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.