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, 2010, Dela Cruz, armed with a knife, entered the house 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 ₱50,000.00.

The prosecution presented eyewitness Maria Santos, the victim’s wife, who testified that she saw Dela Cruz stab her husband and ransack their bedroom. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a fiesta at the time of the incident. The trial court found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua without eligibility for parole, and ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim.

Dela Cruz appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the trial court erred in giving credence to the testimony of the eyewitness.

—

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 the eyewitness.

RULING

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

The Supreme Court affirmed the conviction. The positive identification by eyewitness Maria Santos was clear, consistent, and credible. She had no motive to falsely testify against the accused. Her testimony detailed the events of the robbery and the killing, and she remained steadfast during cross-examination. The Court emphasized that positive identification, when credible and categorical, prevails over alibi and denial.

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

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 crime scene. Dela Cruz failed to establish physical impossibility. The fiesta he attended was in a neighboring city, which was only a few hours away from the crime scene. Thus, it was not impossible for him to have committed the crime and returned to the fiesta.

—

DOCTRINE

The defense of alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible eyewitness. For alibi to be credible, the accused must demonstrate that it was physically impossible for him to be at the crime scene at the time of its commission.

—

DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court finding accused-appellant Juan Dela Cruz GUILTY of Robbery with Homicide is AFFIRMED with MODIFICATION. Accused-appellant is sentenced to reclusion perpetua without eligibility for parole and ordered to pay the heirs of Pedro Santos the following amounts:

– ₱100,000.00 as civil indemnity;
– ₱100,000.00 as moral damages;
– ₱100,000.00 as exemplary damages; and
– ₱50,000.00 as temperate damages.

All monetary awards shall earn interest at the rate of six percent (6%) per annum from the finality of this judgment until fully paid.

SO ORDERED.