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, 2018, in Quezon City, Dela Cruz, armed with a knife, entered the residence 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, fleeing their house immediately after the incident. She also identified the stolen items recovered from Dela Cruz’s possession upon his arrest.

The defense interposed alibi and denial. Dela Cruz claimed he was in a different city attending a family gathering at the time of the crime. He asserted that the stolen items were planted by the police, and the identification by Maria Santos was mistaken due to poor lighting and her distraught state.

The Regional Trial Court (RTC) found Dela Cruz 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 and denial can prevail over positive identification.
3. Whether the aggravating circumstance of dwelling was properly appreciated.

RULING

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

The Court held that the positive identification by eyewitness Maria Santos, who had known the accused prior to the incident, was credible and sufficient to establish Dela Cruz’s presence and participation in the crime. Her testimony was consistent, straightforward, and remained unshaken during cross-examination. The defense failed to show any ill motive for her to falsely testify against the accused.

The recovery of stolen items from Dela Cruz’s possession further corroborated his guilt. The chain of custody was properly established, and the defense’s claim of planting was unsupported by evidence.

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

Alibi is inherently weak and must be supported by clear and convincing evidence that the accused was so far away that it was physically impossible for him to be at the crime scene. Dela Cruz failed to prove the impossibility of his presence. Moreover, denial is an intrinsically weak defense and cannot prevail over the positive testimony of a credible witness.

3. The aggravating circumstance of dwelling was properly appreciated.

Robbery with homicide under Article 294 is punishable by reclusion perpetua to death. The aggravating circumstance of dwelling (that the crime was committed in the victim’s house) was alleged in the Information and proven during trial. However, since the penalty imposed was reclusion perpetua (the lesser penalty within the range), and no other modifying circumstances were present, the trial court correctly imposed reclusion perpetua without further increase.

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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 reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.