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

Ponente: J. PERFECTO

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 valued at ₱50,000. 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 room was well-lit. She claimed she knew the accused as a former neighbor. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in Bulacan attending a fiesta at the time of the incident, which was about 50 kilometers away.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused based on the eyewitness identification, despite the defense of alibi and alleged inconsistencies in the prosecution’s evidence.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of the accused.

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RATIONALE

1. Credibility of Eyewitness Testimony
The Court held that the eyewitness identification by Maria Santos was credible and reliable. She had a clear view of the accused, whom she recognized as a former neighbor, and her testimony remained consistent on material points throughout the trial. The Court emphasized that findings of the trial court on the credibility of witnesses are accorded great weight and respect, as it had the opportunity to observe their demeanor firsthand.

2. Weakness of Alibi as a Defense
The defense of alibi cannot prevail over the positive identification of the accused by a credible witness. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime was committed but also that it was physically impossible for him to have been at the crime scene. Here, the distance between Quezon City and Bulacan (50 km) did not make it impossible for the accused to travel between the two locations within the timeframe of the crime. Thus, the defense of alibi failed.

3. Consistency of Prosecution Evidence
The alleged inconsistencies in the prosecution’s evidence pertained to minor details that did not affect the core narrative of the crime. The Court reiterated that minor inconsistencies may even strengthen the credibility of a witness, as they indicate that the testimony was not rehearsed.

4. Elements of Robbery with Homicide
All elements of Robbery with Homicide were proven beyond reasonable doubt:
(a) The taking of personal property with intent to gain;
(b) The use of violence or intimidation against a person;
(c) The property taken belongs to another;
(d) The taking is characterized by homicide.
The stabbing of Pedro Santos occurred by reason or on the occasion of the robbery, satisfying the qualifying circumstance.

5. Penalty
The penalty for Robbery with Homicide under Article 294 of the Revised Penal Code is reclusion perpetua to death. In the absence of aggravating or mitigating circumstances, the imposition of reclusion perpetua by the lower courts was correct, conforming to prevailing jurisprudence and the prohibition of the death penalty under Republic Act No. 9346.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. 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 suffer the penalty of reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.