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, giving full credence to the eyewitness identification and rejecting the alibi. The RTC sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim. The Court of Appeals (CA) affirmed the RTC decision in toto.

Hence, this appeal before the Supreme Court.

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ISSUES

1. Whether the eyewitness identification of the accused was reliable and sufficient to sustain a conviction beyond reasonable doubt.
2. Whether the defense of alibi should be given credence.
3. Whether the crime committed was Robbery with Homicide or separate crimes of Robbery and Homicide.
4. Whether the damages awarded were proper.

RULING

1. On the reliability of eyewitness identification:
The Supreme Court found the eyewitness identification unreliable. The witness, Maria Santos, claimed recognition under poor lighting conditions, but the Court noted inconsistencies in her testimony regarding the source of light and her line of sight. Moreover, no other evidence corroborated her identification. The Court emphasized that identification must be clear, consistent, and credible to overcome the presumption of innocence. Here, doubt existed because the witness had only a fleeting glance at the perpetrator, who was allegedly wearing a cap that partially covered his face.

2. On the defense of alibi:
While alibi is generally a weak defense, it may be accepted if the accused proves physical impossibility to be at the crime scene. The accused presented witnesses and documentary evidence (photos and testimonies from the fiesta) showing he was in Bulacan. The distance of 50 kilometers and the time frame made it physically impossible for him to be at the crime scene at the time of the incident. The prosecution failed to rebut this evidence.

3. On the nature of the crime:
Given the finding that the prosecution failed to prove the accused’s identity beyond reasonable doubt, the Court did not need to resolve this issue. However, it noted that for Robbery with Homicide to be complexed under Article 294, the killing must be committed by reason or on occasion of the robbery. If the prosecution had proven the elements, the complex crime would stand.

4. On the damages awarded:
Since the accused is acquitted, no civil liability arises. All damages awarded by the lower courts are deleted.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is GRANTED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan dela Cruz for Robbery with Homicide is REVERSED and SET ASIDE. Accused-appellant Juan dela Cruz is ACQUITTED on the ground of reasonable doubt. He is ordered IMMEDIATELY RELEASED from detention unless he is confined for any other lawful cause. Let an entry of final judgment be issued immediately.

SO ORDERED.