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 forcibly took cash and jewelry. During the robbery, Pedro Santos resisted, and in the ensuing struggle, the accused stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused enter their house, demand money, and stab her husband when he refused to comply. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering at the time of the incident.

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 before the Supreme Court.

ISSUE

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

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of the accused for Robbery with Homicide.

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RATIONALE

1. Credibility of Prosecution Witness. The Court upheld the findings of the lower courts regarding the credibility of Maria Santos. Her positive identification of the accused was clear, consistent, and unwavering. The Court emphasized 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 scene of the crime. The accused failed to establish such physical impossibility.

2. Elements of Robbery with Homicide. The Court found all elements present:
– The taking of personal property with intent to gain;
– The taking was with violence or intimidation against persons;
– The property taken belongs to another;
– The taking was unlawful; and
– By reason or on occasion of the robbery, homicide was committed.

The prosecution successfully proved that the homicide was committed by reason or on the occasion of the robbery, as the stabbing occurred when the victim resisted the unlawful taking.

3. Conspiracy and Intent. The accused’s act of stabbing the victim when the latter resisted clearly demonstrated that the killing was intimately connected to the robbery. The Court reiterated that in Robbery with Homicide, the original criminal design of the accused is robbery, and the homicide is committed either as a means to consummate the robbery or on the occasion thereof.

4. Penalty. The Court affirmed the penalty of reclusion perpetua, as the crime was attended by the qualifying circumstance of homicide being committed by reason or on the occasion of the robbery. There being no mitigating or aggravating circumstances, the penalty was properly imposed in its medium period.

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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 Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.