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

Ponente: J. PERFECTO

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 commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz forcibly enter Santos’s house and later flee carrying a bag. She also heard Santos shouting for help before he was killed. The police recovered a bloodied knife at the scene, which forensic examination confirmed had Dela Cruz’s fingerprints and Santos’s blood.

The defense interposed alibi, claiming Dela Cruz was in a different city attending a family gathering at the time of the incident. He presented several relatives to corroborate his presence elsewhere.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua without eligibility for parole. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal before the Supreme Court.

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ISSUES
1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi can prevail over positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated in the crime of robbery.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.

The Supreme Court held that the prosecution successfully established all elements of Robbery with Homicide:
– Taking of personal property The eyewitness saw Dela Cruz flee with a bag belonging to Santos, and several valuables were missing from the house.
– With intent to gain (animus lucrandi) The unlawful taking itself implies intent to gain.
– With violence against or intimidation of persons The use of a knife and the killing of Santos constituted violence.
– Homicide was committed by reason or on occasion of the robbery The killing occurred during the commission of the robbery, as shown by the sequence of events.

The positive identification by eyewitness Maria Reyes was clear, consistent, and credible. She had no motive to falsely testify against Dela Cruz. Her testimony was corroborated by physical evidence (knife with fingerprints and blood).

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

Alibi is inherently weak and must be supported by credible evidence showing the physical impossibility of the accused being at the crime scene. Dela Cruz’s claim of being in another city was not physically impossible, as the distance could be traversed in a few hours. Moreover, alibi crumbles in the face of positive identification by a credible witness.

3. The qualifying circumstance of homicide was properly appreciated.

Robbery with Homicide is a special complex crime under Article 294 of the Revised Penal Code. The homicide need not be intentional; it is enough that the killing occurred by reason or on the occasion of the robbery. Here, the killing was directly linked to the robbery, as the victim resisted the unlawful taking.

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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 is AFFIRMED. Costs against accused-appellant.

SO ORDERED.