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, which was about 50 kilometers away.

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.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused based on the eyewitness identification, despite the defense of alibi and alleged inconsistencies in the prosecution’s evidence.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of the accused.

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RATIONALE

1. Credibility of Eyewitness Testimony
The Court held that the eyewitness identification by Maria Santos was credible and reliable. She had a clear view of the accused, whom she recognized as a former neighbor, and her testimony remained consistent on material points throughout the trial. The Court emphasized that findings of the trial court on the credibility of witnesses are accorded great weight and respect, as it had the opportunity to observe their demeanor firsthand.

2. Weakness of Alibi
The defense of alibi cannot prevail over the positive identification of the accused. 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. The distance of 50 kilometers between Bulacan and Quezon City did not render it impossible for the accused to have traveled to the crime scene. Thus, the alibi defense failed.

3. Consistency of Prosecution Evidence
The alleged inconsistencies in the prosecution’s evidence pertained to minor details that did not affect the core narrative of the crime. The Court reiterated that minor inconsistencies may even strengthen the credibility of a witness, as they indicate that the testimony was not rehearsed.

4. Qualifying Circumstance of Homicide
The Court found that the killing was committed by reason or on the occasion of the robbery, as the victim was stabbed when he resisted the unlawful taking. Thus, the crime was properly classified as Robbery with Homicide under Article 294(1) of the Revised Penal Code.

5. Penalty
The penalty for Robbery with Homicide is reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the RTC correctly imposed reclusion perpetua, in accordance with prevailing jurisprudence.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. 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.