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, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family reunion at the time of the incident. The trial court convicted Dela Cruz and sentenced him to reclusion perpetua. The Court of Appeals affirmed the conviction. 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 can prevail over positive identification by an eyewitness.

RULING

1. Yes, the prosecution proved the guilt of the accused beyond reasonable doubt.

The Court held that the prosecution evidence, particularly the positive identification by eyewitness Maria Reyes, was credible and sufficient to establish Dela Cruz’s guilt. Reyes testified in a clear, consistent, and straightforward manner, and her testimony remained unshaken during cross-examination. The Court emphasized that positive identification, when categorical and consistent, prevails over alibi and denial.

2. No, the defense of alibi cannot prevail over positive identification.

The defense of alibi is inherently weak and must be supported by clear and convincing evidence that the accused was so far away that it was physically impossible for him to be at the scene of the crime. Dela Cruz failed to prove this impossibility. The family reunion he allegedly attended was in a neighboring city, which was only a few hours away by public transportation. Hence, it was not physically impossible for him to have been at the crime scene.

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DOCTRINE

The defense of alibi cannot prevail over the positive identification of the accused by a credible eyewitness, unless the accused demonstrates that it was physically impossible for him to be at the scene of the crime at the time of its commission.

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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 Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.