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 commission of the robbery, Dela Cruz stabbed Santos, causing his death. The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene with a bag containing stolen items.

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. The defense presented the testimonies of Dela Cruz’s relatives to corroborate his alibi.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The RTC gave full credence to the eyewitness testimony of Maria Reyes and rejected the defense of alibi for being weak and unsubstantiated. 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 defense of alibi should be given credence over the positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated to convict the accused of Robbery with Homicide.

RULING

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

The Supreme Court held that the prosecution successfully established all the elements of Robbery with Homicide:

– Taking of personal property belonging to another proven by the missing items and the eyewitness account of the accused fleeing with a bag.
– With intent to gain (animus lucrandi) inferred from the unlawful taking.
– With violence or intimidation against persons the accused was armed with a knife and used force against the victim.
– Homicide was committed as a consequence or on the occasion of the robbery the killing was directly linked to the robbery, as the victim was killed to facilitate the taking or to eliminate a witness.

The positive identification by eyewitness Maria Reyes, who had no ill motive to testify falsely, was clear, consistent, and credible. The Court emphasized that positive identification prevails over alibi, especially when the witness had a good opportunity to observe the accused under well-lighted conditions.

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

The defense of 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 was committed but also that it was physically impossible for him to be at the scene of the crime. In this case, Dela Cruz failed to prove physical impossibility. The distance between the crime scene and the place where he claimed to be was not so great as to preclude his presence at the locus criminis. Moreover, the testimonies of his relatives, being inherently biased, lacked the impartiality required for corroboration.

3. The qualifying circumstance of homicide was properly appreciated.

Robbery with Homicide is a special complex crime where the homicide is treated as an aggravating circumstance inherent in the crime itself. The prosecution proved that the killing was intimately connected to the robberyit was committed to facilitate the robbery or to eliminate opposition. The simultaneousness of the robbery and the killing was established by the eyewitness account and the circumstantial evidence.

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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 reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.