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, 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, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a fiesta 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 over the positive identification by the eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated to convict the accused of Robbery with Homicide.

RULING

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

The Court held that the positive identification of the accused by the eyewitness, Maria Santos, was clear, consistent, and credible. She had a sufficient opportunity to see the accused during the incident as the house was well-lit, and she was face-to-face with him for several minutes. Her testimony remained unwavering even during cross-examination.

The defense’s attempt to impeach her credibility by alleging inconsistencies in her statements was unavailing. The alleged inconsistencies pertained to minor details that did not affect the core of her testimony—that she saw the accused rob and kill her husband.

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

The Court reiterated the well-established doctrine that alibi is the weakest defense 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 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.

In this case, the accused failed to prove the physical impossibility. The fiesta he claimed to have attended was in a neighboring city, which was only an hour’s drive from the crime scene. Therefore, it was not impossible for him to have been at the locus criminis.

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 prosecution successfully established the elements: (a) the taking of personal property with violence or intimidation; (b) the property belongs to another; (c) the taking is with animo lucrandi; and (d) on the occasion or by reason of the robbery, homicide was committed.

The killing of Pedro Santos was integral to the robbery, as it was done to facilitate the taking or to ensure the accused’s escape. The single intent to commit robbery subsumed the resulting homicide.

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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 is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.