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 recognized him because the room was well-lit. She also testified that she heard her husband shouting the accused’s name during the struggle.

The defense interposed the defense of alibi, claiming that the accused was in a different city attending a family reunion at the time of the incident. The accused presented several family members to corroborate his alibi.

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.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused for Robbery with Homicide despite the failure of the prosecution to prove his guilt beyond reasonable doubt.

RULING

NO, the Court of Appeals did not err. The conviction is affirmed.

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RATIONALE

The Supreme Court held that alibi is inherently a weak defense and cannot prevail over the positive identification of the accused by a credible eyewitness. In this case, Maria Santos gave a clear, consistent, and categorical testimony that she saw the accused inside their house during the robbery and heard her husband shout his name. Her testimony was straightforward and remained unshaken during cross-examination.

The Court emphasized that 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. Here, the accused failed to establish the physical impossibility of his presence at the crime scene. The place where he claimed to be was only a few hours away by vehicle, making it possible for him to have committed the crime and returned.

Moreover, the Court found no ill motive on the part of the eyewitness to falsely testify against the accused. The defense failed to present any evidence of grudge or improper motive that could have impelled Maria Santos to commit perjury.

The elements of Robbery with Homicide were sufficiently established:
1. The taking of personal property with intent to gain;
2. The taking was accomplished with violence or intimidation against a person;
3. On the occasion of the robbery, homicide was committed.

The killing of Pedro Santos was proven to have occurred by reason or on the occasion of the robbery. The taking of the cash and jewelry and the killing were part of a single criminal act.

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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 Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.