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, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz forcibly enter Santos’ house and later flee carrying a bag. She also heard Santos shouting for help. The police recovered a bloodied knife near the crime scene, which forensic analysis confirmed had Dela Cruz’s fingerprints and Santos’ blood.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. Several relatives testified to corroborate his presence elsewhere.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt, sentencing him to reclusion perpetua without eligibility for parole. The RTC gave greater weight to the eyewitness testimony and forensic evidence, dismissing the alibi as weak and unsubstantiated.

On appeal, the Court of Appeals (CA) affirmed the RTC decision in toto. Dela Cruz now appeals to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the lower courts erred in disregarding his alibi.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt for Robbery with Homicide.
2. Whether the defense of alibi should be given credence in light of the positive identification by an eyewitness.

RULING

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

The Supreme Court upheld the conviction. The elements of Robbery with Homicide are: (a) the taking of personal property with intent to gain; (b) the taking was with violence or intimidation against persons; and (c) on the occasion of the robbery, homicide was committed.

All elements were established:
– Taking of property: Maria Reyes testified she saw Dela Cruz flee with a bag, and the victim’s family confirmed cash and jewelry were missing.
– Violence/intimidation: The forcible entry and use of a knife constituted violence.
– Homicide on occasion of robbery: The killing occurred during the robbery, as shown by the sequence of events and the recovery of the stolen property from Dela Cruz’s possession.

The positive identification by eyewitness Maria Reyes, who had no motive to falsely testify, was clear and consistent. Her testimony was corroborated by forensic evidence—the knife with Dela Cruz’s fingerprints and the victim’s blood. The defense failed to impute any ill motive on her part.

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

The Court reiterated the doctrine that alibi is inherently weak and must be supported by credible corroboration. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to be at the crime scene.

Dela Cruz claimed he was in a different city, but the travel distance was only three hours by vehicle. Hence, it was not physically impossible for him to be at the crime scene. Moreover, alibi yields to positive identification, especially when the witness is credible and the identification is categorical.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the conviction of Juan Dela Cruz for Robbery with Homicide and sentencing him to reclusion perpetua without eligibility for parole is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.