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 Santos, the victim’s wife, who testified that she saw the accused inside their house and recognized him because the room was well-lit. She claimed she knew the accused as a former neighbor. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in Bulacan attending a fiesta at the time of the incident, supported by the testimonies of his relatives.

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.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should prevail over the positive identification by the eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated to convict 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 of the accused 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 named the accused as his assailant before expiring. The defense failed to impeach her credibility.

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

The Court reiterated the doctrine that alibi is the weakest defense and must be supported by credible corroboration. For alibi to prosper, the accused must prove not only that he was somewhere else when the crime was committed but also that it was physically impossible for him to have been at the crime scene. Here, the accused failed to show that it was impossible for him to travel from Bulacan to Quezon City within the timeframe of the crime. Hence, alibi must yield to positive identification.

3. The qualifying circumstance of homicide was properly appreciated.

Robbery with Homicide is a special complex crime where the homicide may be either intentional or incidental. The prosecution established that the killing occurred by reason or on the occasion of the robbery. The fact that the victim was killed while resisting the robbery satisfies the element of the crime. The accused’s intent to gain (animus lucrandi) was proven by the taking of cash and jewelry.

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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 is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.