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 forcibly took cash and jewelry. During the robbery, Pedro Santos resisted, and a struggle ensued, resulting in the accused stabbing and killing Pedro Santos.

The prosecution presented eyewitness testimony from Maria Santos, the victim’s wife, who positively identified Juan Dela Cruz as the perpetrator. She testified that she saw the accused inside their house, holding a knife, and witnessed him stab her husband. The prosecution also presented circumstantial evidence, including the recovery of the stolen items in the accused’s possession and his alleged flight after the incident.

The defense interposed the defense of alibi, claiming that Juan Dela Cruz was in a different city at the time of the crime, attending a family gathering. He presented witnesses, including family members, to corroborate his alibi.

The Regional Trial Court (RTC) found Juan Dela Cruz guilty beyond reasonable doubt of Robbery with Homicide and sentenced him to reclusion perpetua. The court gave full credence to the eyewitness identification and rejected the defense of alibi for being weak and unsubstantiated.

On appeal, 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 prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should be given credence over positive identification.
3. Whether the qualifying circumstance of homicide was properly appreciated in the crime of robbery.

RULING

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

The Supreme Court affirmed the conviction. The Court held that the positive identification of the accused by eyewitness Maria Santos was clear, categorical, and consistent. Her testimony withstood rigorous cross-examination, and no ill motive was shown for her to falsely testify against the accused. The Court emphasized that positive identification, when credible and categorical, prevails over alibi and denial.

Furthermore, the stolen items were recovered from the accused, corroborating the robbery aspect of the crime. His flight after the incident was also considered an indication of guilt.

2. The defense of alibi cannot prevail over positive identification.

The defense of alibi is inherently weak and must be established with clear and convincing evidence that the accused was at another place at the time of the commission of the crime and that it was physically impossible for him to be at the crime scene. In this case, the accused failed to prove the physical impossibility of his presence at the crime scene. The distance between the location of the alibi and the crime scene was not so great as to preclude his presence. The testimony of his witnesses, being relatives, was also deemed insufficient and self-serving.

3. The crime committed is Robbery with Homicide.

The Court ruled that all elements of Robbery with Homicide were present: (a) the taking of personal property with violence or intimidation against a person; (b) the property taken belongs to another; (c) the taking is done with animo lucrandi (intent to gain); and (d) on the occasion or by reason of the robbery, homicide is committed. The killing of Pedro Santos was directly linked to and occurred by reason of the robbery, as the violence employed to carry out the robbery resulted in his death. The trial court correctly appreciated the special complex 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 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.