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, 2010, in Quezon City, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, and took cash and jewelry. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw Dela Cruz, whom she recognized as a former neighbor, inside their house holding a knife and standing over her husband’s body. She also testified that she saw him take a jewelry box. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in Bulacan attending a fiesta at the time of the incident. The defense presented two witnesses to corroborate his alibi.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The RTC gave full credence to the eyewitness identification and rejected the alibi for being weak and unsubstantiated. 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 be given credence 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 the eyewitness, Maria Santos, was clear, categorical, and consistent. She had known the accused for years as a former neighbor, and there was no ill motive for her to falsely testify against him. The defense failed to impeach her credibility. The Court reiterated the doctrine that positive identification prevails over alibi and denial.

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

The defense of alibi requires not only proof that the accused was somewhere else when the crime was committed but also that it was physically impossible for him to be at the scene of the crime. Here, the defense merely claimed that Dela Cruz was in Bulacan, a neighboring province, which is not physically impossible to travel from to Quezon City within a few hours. Hence, the alibi was correctly rejected.

3. The qualifying circumstance of homicide was properly appreciated.

For Robbery with Homicide, it is sufficient that the homicide be committed by reason or on the occasion of the robbery. The prosecution proved that the killing occurred during the commission of the robbery, as the eyewitness saw the accused inside the house, armed, standing over the victim after taking the jewelry box. The intent to rob was evident from the taking of property, and the killing was integral to the commission of the robbery.

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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.