G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. PERFECTO

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, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Reyes, a neighbor 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 attending a festival at the time of the incident. The trial court convicted Dela Cruz and sentenced him to reclusion perpetua. He appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide.

RULING

NO. The Supreme Court AFFIRMED the conviction.

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RATIONALE

1. Elements of Robbery with Homicide. The crime of Robbery with Homicide under Article 294(1) of the Revised Penal Code requires: (a) the taking of personal property with violence or intimidation against a person; (b) the property taken belongs to another; (c) the taking is done with animus lucrandi (intent to gain); and (d) on the occasion or by reason of the robbery, homicide is committed. All these elements were established beyond reasonable doubt.

2. Credibility of Prosecution Witness. The testimony of eyewitness Maria Reyes was clear, consistent, and credible. She positively identified Dela Cruz as the person she saw fleeing the victim’s house immediately after the crime. The Court gives great weight to the trial court’s assessment of witness credibility, as it had the opportunity to observe the witness’s demeanor.

3. Weakness of Alibi. Dela Cruz’s defense of alibi cannot prevail over the positive identification by a credible witness. 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 scene of the crime. Dela Cruz failed to establish physical impossibility, as the festival he attended was in a nearby city, still accessible within hours.

4. Chain of Custody and Evidence. The stolen items were recovered from Dela Cruz’s house through a validly issued search warrant. The chain of custody was properly established, and the evidence was admissible. The recovery of the stolen property in his possession shortly after the crime supports his guilt.

5. Conspiracy and Intent. The killing occurred by reason or on the occasion of the robbery. The use of a knife and the violent taking of property show a unity of purpose to commit robbery, and the homicide was a consequence thereof. The intent to gain (animus lucrandi) is presumed from the unlawful taking.

6. Penalty. Robbery with Homicide is punishable by reclusion perpetua to death. In the absence of aggravating circumstances, the penalty of reclusion perpetua imposed by the trial court is correct. Civil indemnity, moral damages, and exemplary damages awarded to the heirs of the victim are also affirmed in accordance with prevailing jurisprudence.

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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.

SO ORDERED.