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 robbery, Dela Cruz stabbed Santos, causing his death, and took cash and jewelry.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz forcibly enter Santos’ house and later flee with a bag. The police recovered the stolen items from Dela Cruz’s possession three days after the incident. Dela Cruz interposed the defense of alibi, claiming he was in a different city at the time of the crime.

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, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the eyewitness testimony was unreliable.

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

The Supreme Court upheld the conviction. The Court emphasized that positive identification by a credible eyewitness prevails over alibi and denial. Maria Reyes’ testimony was clear, consistent, and categorical. She had no motive to falsely testify against Dela Cruz. Her testimony was corroborated by the physical evidencethe stolen items recovered from Dela Cruz.

The elements of Robbery with Homicide were all present:
– Taking of personal property with intent to gain proven by the stolen items found in Dela Cruz’s possession.
– Use of violence or intimidation against a person proven by the forcible entry and stabbing.
– Homicide committed by reason or on occasion of the robbery the killing was directly linked to the robbery, as it occurred during its commission.

The Court found the chain of custody of the stolen items intact and the evidence sufficient to sustain conviction.

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

The Court reiterated the doctrine that alibi is inherently weak and must be supported by clear and convincing evidence of the physical impossibility of the accused being at the crime scene. Dela Cruz failed to prove it was physically impossible for him to be at the locus criminis. The distance between the crime scene and his alleged location was not insurmountable, and no credible witnesses corroborated his alibi.

Positive identification, when credible and categorical, will always overcome alibi.

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DISPOSITIVE PORTION

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

Costs against accused-appellant.

SO ORDERED.