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 Santos, the victim’s wife, who testified that she saw Dela Cruz, whom she knew personally, stab her husband. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in Bulacan, 50 kilometers away, at the time of the incident, attending a family gathering. Several relatives corroborated his alibi.

The Regional Trial Court (RTC) convicted Dela Cruz, giving full credence to the eyewitness identification and rejecting the alibi. The Court of Appeals (CA) affirmed the RTC decision. 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 upheld over the positive identification by an eyewitness.

RULING

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

The Court affirmed the conviction. Positive identification by a credible eyewitness prevails over the defense of alibi. Maria Santos gave a clear, consistent, and categorical testimony that she saw Dela Cruz stab her husband. She had no ill motive to falsely testify against him. Her identification was made under sufficient lighting conditions, and she knew Dela Cruz prior to the incident, making her identification highly reliable.

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. Dela Cruz’s claim of being in Bulacan, a mere 50 kilometers away, did not meet this standard. Travel between Bulacan and Quezon City is possible within a short period, making his presence at the crime scene physically possible. The testimony of his relatives, being inherently biased, could not overcome the positive identification by the eyewitness.

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DOCTRINE

Positive identification by a credible witness, who has no motive to testify falsely, prevails over the defense of alibi and denial. 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.

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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 Robbery with Homicide is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.