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 forcibly took cash and jewelry. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and witnessed the stabbing. The defense, however, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering at the time of the incident.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal before the Supreme Court.

—

ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi can prevail over the positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Supreme Court AFFIRMED the conviction. The positive identification by eyewitness Maria Santos was clear, categorical, and consistent. She had no ill motive to falsely testify against the accused. Her testimony was corroborated by physical evidence and the dying declaration of the victim, who identified the accused before succumbing to his injuries.

2. On the defense of alibi.

The defense of alibi must be rejected. Jurisprudence consistently holds that alibi is inherently weak and cannot prevail over the positive identification of the accused 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 be at the scene of the crime. The accused failed to establish physical impossibility, as the location of the family gathering was merely a few hours away from the crime scene.

3. On the qualifying circumstance of homicide.

The crime committed is Robbery with Homicide. Under Article 294, when homicide is committed by reason or on occasion of the robbery, it is treated as a single special complex crime. The prosecution established that the killing was intimately connected to the robbery; the homicide occurred while the accused was fleeing after taking the items. Thus, the qualifying circumstance was properly appreciated.

—

DISPOSITIVE PORTION

WHEREFORE, the Decision of the Court of Appeals is AFFIRMED. Accused-appellant JUAN DELA CRUZ is found GUILTY beyond reasonable doubt of the crime of Robbery with Homicide and is sentenced to suffer the penalty of reclusion perpetua. He is ordered to pay the heirs of Pedro Santos civil indemnity, moral damages, exemplary damages, and actual damages, with interest at the legal rate until fully paid.

SO ORDERED.