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

Ponente: J. PERFECTO

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, a struggle ensued, and Dela Cruz fatally stabbed Santos.

The prosecution presented eyewitness testimony from Maria Santos, the victim’s wife, who positively identified Dela Cruz as the perpetrator. She testified that she saw Dela Cruz enter their house, demand money, and stab her husband when he resisted. The prosecution also presented circumstantial evidence, including Dela Cruz’s flight from the scene and his possession of the victim’s wallet, which was recovered by police.

The defense interposed the alibi that Dela Cruz was at a friend’s house in a different barangay at the time of the incident. He denied any involvement in the crime and claimed that the wallet was planted by the police.

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 alibi of the accused should be given credence over the positive identification by the eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated in convicting the accused of Robbery with Homicide.

RULING

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

The Court held that the positive identification by eyewitness Maria Santos was clear, consistent, and credible. 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 categorical and consistent, prevails over alibi and denial, which are inherently weak defenses.

Moreover, the recovery of the victim’s wallet from Dela Cruz, coupled with his flight from the scene, constituted strong circumstantial evidence of guilt. Flight is an indication of guilt, and when combined with positive identification, it strengthens the case against the accused.

2. The alibi of the accused 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 scene of the crime. Dela Cruz failed to establish physical impossibility. The distance between his alleged location and the crime scene was not so great as to preclude his presence at the latter. Hence, his alibi must fail.

3. The qualifying circumstance of homicide was properly appreciated.

Robbery with Homicide is a special complex crime where the homicide may occur by reason or on occasion of the robbery. It is not necessary that the homicide be intended; it is sufficient that the killing is connected to the robbery. In this case, the killing of Pedro Santos occurred when he resisted the robbery, clearly making the homicide incidental to the robbery. Thus, the crime was correctly classified as Robbery with Homicide.

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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.