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, 2018, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and recognized him because the light from a nearby streetlamp illuminated his face. She also testified that she heard the accused demand money from her husband before stabbing him.

The defense, on the other hand, interposed the defense of alibi. Accused-appellant claimed that at the time of the incident, he was in a different barangay attending a birthday party, and he presented several witnesses to corroborate his presence there.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt, giving full credence to the eyewitness identification and rejecting 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 eyewitness identification of the accused was reliable and sufficient to sustain a conviction.
2. Whether the defense of alibi should have been given credence in light of the positive identification by the prosecution witness.
3. Whether the crime committed was properly qualified as Robbery with Homicide.

RULING

1. On the reliability of the eyewitness identification:
The Court found the eyewitness identification reliable. Maria Santos had a clear view of the accused under sufficient illumination from a nearby streetlamp. She had no motive to falsely testify against the accused. Moreover, her testimony was straightforward and consistent on material points. The Court has consistently held that positive identification, when categorical and consistent and without any ill motive on the part of the eyewitness, prevails over alibi and denial.

2. On the defense of alibi:
The defense of alibi was rightly rejected. For alibi to prosper, 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. Here, the distance between the locus criminis and the place where the accused claimed to be was not so considerable as to preclude his presence at the crime scene. Alibi is inherently weak and cannot prevail over positive identification.

3. On the proper crime:
The Court affirmed that the crime committed was Robbery with Homicide. The elements were all present: (a) the taking of personal property with intent to gain; (b) with violence or intimidation against persons; (c) the property taken belongs to another; and (d) on the occasion of the robbery, homicide was committed. The killing was perpetrated by reason or on the occasion of the robbery, as evidenced by the demand for money and the immediate stabbing thereafter.

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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 is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.