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 Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in Bulacan, 50 kilometers away, at the time of the incident, attending a family reunion. Several relatives corroborated his alibi.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt, giving full credence to the eyewitness testimony and rejecting the alibi. The RTC sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim. The Court of Appeals affirmed the RTC decision in toto.

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 an eyewitness.
3. Whether the penalty imposed is correct.

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 Reyes was clear, categorical, and consistent. She had no ill motive to falsely testify against the appellant. Her testimony on the material pointsthe identity of the perpetrator, the act of stabbing, and the taking of personal propertyremained unshaken on cross-examination.

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

The Court reiterated the well-established doctrine that alibi is the weakest of all defenses and must be rejected when the accused has been positively identified by a credible witness. 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 scene of the crime. The distance of 50 kilometers between Bulacan and Quezon City, traversable by vehicle in about 12 hours, did not constitute physical impossibility. Thus, the defense of alibi must fail.

3. The penalty imposed is correct.

Robbery with Homicide under Article 294(1) of the Revised Penal Code 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 award of damages is also affirmed, following prevailing jurisprudence.

DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan Dela Cruz for the crime of Robbery with Homicide and sentencing him to suffer the penalty of reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.