G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. Reyes

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, 2015, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the robbery, Dela Cruz stabbed Santos, causing his death. The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene with a bag containing Santos’s belongings.

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

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The RTC gave more weight to the positive identification by the eyewitness over the defense of alibi. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal before the Supreme Court.

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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 prevail over the positive identification by an eyewitness.
3. Whether the qualifying circumstance of “with the use of a deadly weapon” was properly appreciated.

RULING

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

The Supreme Court held that the prosecution successfully established all the elements of Robbery with Homicide:
– Taking of personal property belonging to another;
– With intent to gain (animus lucrandi);
– With violence or intimidation against persons;
– Homicide was committed by reason or on occasion of the robbery.

The eyewitness testimony of Maria Reyes was found to be clear, credible, and consistent. She had no ill motive to falsely testify against the accused. Her positive identification, made under well-lit conditions and without hesitation, prevails over the defense of alibi.

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

The Court reiterated the well-settled doctrine that 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 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. Dela Cruz failed to prove physical impossibility, as the city where he claimed to be was only a few hours away from the crime scene.

3. The qualifying circumstance of “with the use of a deadly weapon” was properly appreciated.

The use of a knife, a deadly weapon, was sufficiently proven by the prosecution through the eyewitness account and the medico-legal report confirming stab wounds as the cause of death. This circumstance qualifies the crime to Robbery with Homicide under Article 294(1) of the RPC.

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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 the crime of Robbery with Homicide and sentencing him to suffer the penalty of reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.