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, 2015, 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 Lopez, a neighbor who claimed to have seen Dela Cruz fleeing the scene. The defense, however, presented an alibi, asserting that Dela Cruz was in a different city attending a family reunion at the time of the crime. The trial court convicted Dela Cruz, giving full credence to the eyewitness testimony and rejecting the alibi. The court sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to the victim’s heirs.

Dela Cruz appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, highlighting inconsistencies in the eyewitness’s testimony and the weak corroboration of the alibi.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the trial court erred in giving credence to the eyewitness testimony despite alleged inconsistencies.
3. Whether the defense of alibi should have been given weight.

RULING

1. On the proof of guilt beyond reasonable doubt:
The Supreme Court AFFIRMED the conviction. The Court held that the prosecution successfully established all elements of Robbery with Homicide: (a) the taking of personal property with intent to gain, (b) with violence or intimidation against a person, (c) and on the occasion of the robbery, homicide was committed. The eyewitness testimony of Maria Lopez was clear, consistent, and credible. Minor inconsistencies in her testimony referred to trivial details and did not affect the core of her account.

2. On the credibility of the eyewitness:
The Court upheld the trial court’s assessment of the eyewitness’s credibility. The trial judge had the unique opportunity to observe the witness’s demeanor, and absent any showing of ill motive, her testimony deserved full faith and credit. The alleged inconsistencies were not material and did not cast doubt on her positive identification of the accused.

3. On the defense of alibi:
The Court REJECTED the defense of alibi. 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 scene of the crime. Dela Cruz failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable. Moreover, alibi is inherently weak and cannot prevail over the positive identification by a credible eyewitness.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court convicting accused-appellant Juan Dela Cruz of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.