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, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the robbery, Santos resisted, and Dela Cruz stabbed him multiple times, causing his death. Dela Cruz then took cash and jewelry worth ₱50,000.

During trial, the prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene of the crime carrying a bag. The police recovered the stolen items from Dela Cruz’s house pursuant to a search warrant. Dela Cruz interposed the defense of alibi, claiming he was in a different city at the time of the incident. 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.

Dela Cruz appealed to the Supreme Court, arguing that: (1) the prosecution failed to prove his guilt beyond reasonable doubt; (2) the search warrant was illegally procured; and (3) his defense of alibi should have been given credence.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the search warrant was validly issued.
3. Whether the defense of alibi should prevail over the positive identification by the eyewitness.

RULING

1. On the proof of guilt beyond reasonable doubt.
The Supreme Court affirmed the conviction. The prosecution successfully established all elements of Robbery with Homicide: (a) the taking of personal property with intent to gain; (b) with violence or intimidation against a person; (c) the property taken belongs to another; (d) the taking is without the consent of the owner; and (e) on the occasion of the robbery, homicide was committed. The eyewitness testimony of Maria Reyes was clear, consistent, and credible. Her positive identification of Dela Cruz as the perpetrator prevailed over his bare denial and alibi.

2. On the validity of the search warrant.
The Court held that the search warrant was validly issued. The application and supporting affidavits sufficiently established probable cause, describing with particularity the place to be searched and the items to be seized. The police complied with the constitutional and procedural requirements for the issuance of a search warrant. Thus, the items seized were admissible in evidence.

3. On the defense of alibi.
The defense of alibi must fail. Alibi is inherently weak 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 elsewhere when the crime was committed but also that it was physically impossible for him to have been at the scene of the crime. Dela Cruz failed to establish physical impossibility, as the distance between his alleged location and the crime scene was not insurmountable.

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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 is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.