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(1) 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 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 witnessed the stabbing. The defense, however, interposed the defense of alibi, claiming that the accused was in a different city 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.

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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.
3. Whether the qualifying circumstance of homicide was properly appreciated.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Court AFFIRMED the conviction. The positive identification by the eyewitness, Maria Santos, who had no ill motive to testify falsely, prevailed over the denial and alibi of the accused. Her testimony was clear, consistent, and credible. The defense failed to show any reason why she would falsely accuse the appellant.

2. On the defense of alibi.

The defense of alibi was REJECTED. 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 accused failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable.

3. On the qualifying circumstance.

The Court HELD that the crime committed was indeed Robbery with Homicide. The homicide was committed by reason or on the occasion of the robbery, as the stabbing occurred while the accused was fleeing after taking the items. The single penalty for the special complex crime of Robbery with Homicide is reclusion perpetua to death. Given the absence of aggravating circumstances, the penalty of reclusion perpetua was correctly imposed.

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DISPOSITIVE PORTION

WHEREFORE, the Decision of the Court of Appeals is AFFIRMED. Accused-appellant Juan dela Cruz is found GUILTY beyond reasonable doubt of the crime of Robbery with Homicide and is sentenced to suffer the penalty of reclusion perpetua. He is ordered to pay the heirs of Pedro Santos civil indemnity, moral damages, exemplary damages, and actual damages, with interest at the legal rate of six percent (6%) per annum from the finality of this judgment until fully paid.

SO ORDERED.