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

Ponente: J. Reyes

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 robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented eyewitness testimony from Maria Santos, the victim’s wife, who identified Dela Cruz as the perpetrator. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in a different city at the time of the incident.

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.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for Robbery with Homicide despite the alleged weakness of the prosecution’s evidence and the strength of his alibi.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide.

—

RATIONALE

1. Credibility of Prosecution Witness.
The Court upheld the findings of the RTC and CA regarding the credibility of eyewitness Maria Santos. The witness gave a clear, consistent, and straightforward account of the incident. Her positive identification of Dela Cruz as the perpetrator was categorical and unwavering. The Court emphasized that findings of trial courts on witness credibility are accorded great weight and respect, as they are in a better position to observe the witnesses’ demeanor, unless there is a clear showing of error or arbitrariness. No such error was found here.

2. Alibi as a Defense.
The Court reiterated the well-settled doctrine 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 have been at the crime scene. Dela Cruz failed to establish physical impossibility. His claim of being in a different city was unsupported by convincing evidence and was deemed insufficient to overturn his positive identification.

3. Elements of Robbery with Homicide.
The Court found all elements of Robbery with Homicide present:
(a) The taking of personal property with intent to gain;
(b) The taking was accomplished with violence or intimidation against a person;
(c) The robbery resulted in homicide.
The prosecution proved that Dela Cruz entered the victim’s house, demanded money, and during the struggle, killed the victim. The homicide was committed by reason or on occasion of the robbery, making the special complex crime applicable.

4. Penalty.
Under Article 294 of the Revised Penal Code, Robbery with Homicide is punishable by reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the penalty of reclusion perpetua was correctly imposed by the lower courts. The Court also affirmed the award of civil indemnity, moral damages, and exemplary damages to the heirs of the victim, consistent with prevailing jurisprudence.

—

DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. 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.