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

Ponente: J. PERFECTO

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 commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz forcibly enter Santos’s house and later flee carrying a bag. She also heard Santos shouting for help. The police recovered a bloodied knife near the crime scene, which was later identified through fingerprint analysis as bearing Dela Cruz’s prints. Dela Cruz interposed the defense of alibi, claiming he was in a different city attending a family gathering at the time of the incident. He presented his sister and a friend to corroborate his whereabouts.

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 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 prevail over the positive identification by an eyewitness.
3. Whether the aggravating circumstance of dwelling was properly appreciated.

RULING

1. On the proof of guilt beyond reasonable doubt YES.

The Court held that 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 unlawful; and (e) by reason or on occasion of the robbery, homicide was committed.

The eyewitness account of Maria Reyes was clear, consistent, and credible. She had no motive to falsely testify against the accused. Her testimony was corroborated by physical evidencethe bloodied knife with Dela Cruz’s fingerprints found near the scene. The defense failed to impeach her credibility or show any ill motive.

2. On the defense of alibi vs. positive identification NO, alibi cannot prevail.

The Court reiterated the 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 elsewhere when the crime was committed but also that it was physically impossible for him to be at the crime scene. Dela Cruz claimed he was in a different city, but the distance was only about 50 kilometers, travelable by vehicle within an hour. Hence, it was not physically impossible for him to be present at the crime scene.

3. On the aggravating circumstance of dwelling YES, it was properly appreciated.

The crime was committed in the victim’s house, which is an aggravating circumstance under Article 14 of the Revised Penal Code. The prosecution proved that the accused deliberately entered the dwelling of Santos to commit robbery, and the killing occurred therein. This qualifies the crime for the imposition of the maximum penalty, but since Robbery with Homicide is punishable by reclusion perpetua to death, and no other modifying circumstances were present, the penalty of reclusion perpetua was correctly imposed.

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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 and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.