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 and killed.

The prosecution presented an eyewitness, Maria Reyes, a neighbor, who testified that she saw dela Cruz fleeing the scene of the crime carrying a bag. The police recovered a knife with fingerprints matching dela Cruz at the crime scene. The accused interposed the defense of alibi, claiming he was in a different city attending a family reunion at the time of the incident. The trial court found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua. 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 over the positive identification by an eyewitness.

RULING

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

The Court affirmed the conviction. The positive identification by eyewitness Maria Reyes, who had no motive to falsely testify, was clear and credible. Her testimony was consistent and withstood rigorous cross-examination. The fingerprint evidence on the murder weapon corroborated her account. The defense failed to show any ill motive on the part of the witness that would cast doubt on her testimony.

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

The defense of 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 physical impossibility of his presence at the crime scene. The location of his alibi was not so distant as to preclude his presence in Quezon City at the time of the robbery-homicide. Positive identification, when categorical and consistent, will almost always prevail over alibi.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court, Branch 90, Quezon City, finding accused-appellant JUAN DELA CRUZ guilty beyond reasonable doubt of the crime of Robbery with Homicide and sentencing him to reclusion perpetua, is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.