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, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the robbery, Dela Cruz stabbed Santos, causing his death, and took cash and jewelry amounting to ₱50,000.

The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene of the crime carrying a bag. The police recovered the stolen items from Dela Cruz’s house pursuant to a search warrant. Dela Cruz interposed the defense of alibi, claiming he was in a different city at the time of the incident.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the warrantless search and seizure of the stolen items from the accused’s house is valid.
3. Whether the penalty imposed is correct.

RULING

1. On the proof of guilt beyond reasonable doubt.
The Court found that the prosecution failed to prove the guilt of the accused beyond reasonable doubt. The lone eyewitness, Maria Reyes, did not actually witness the stabbing or the taking of property. She only saw the accused fleeing the area, which is insufficient to establish all elements of Robbery with Homicide. The circumstantial evidence presented did not constitute an unbroken chain leading to the conclusion that Dela Cruz is guilty. Hence, the constitutional presumption of innocence prevails.

2. On the validity of the warrantless search and seizure.
The Court ruled that the warrantless search was invalid. The search was conducted based merely on police suspicion without any exigent circumstance that would justify a warrantless search under recognized exceptions (e.g., search incidental to lawful arrest, plain view, consented search, etc.). The items seized are therefore inadmissible in evidence under the exclusionary rule (Section 3(2), Article III, 1987 Constitution ).

3. On the correctness of the penalty.
In view of the failure of the prosecution to prove guilt beyond reasonable doubt, the Court did not reach the issue of penalty.

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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. The Director of the Bureau of Corrections is ordered to cause his immediate release, unless he is being held for some other lawful cause.

SO ORDERED.