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, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented eyewitness testimony from Maria Santos, the victim’s wife, who positively identified Dela Cruz as the perpetrator. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz 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 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 can prevail over positive identification.
3. Whether the qualifying circumstance of “with homicide” was properly appreciated.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Court ruled in the affirmative. The prosecution successfully established all the 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; and (d) on the occasion of the robbery, homicide was committed.

The positive identification by eyewitness Maria Santos was clear, consistent, and credible. She testified that she saw Dela Cruz enter their house, demand money, and stab her husband when he resisted. Her testimony was corroborated by physical evidence and the recovery of the stolen items in Dela Cruz’s possession.

2. On the defense of alibi versus positive identification.

The defense of alibi 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 crime scene. Dela Cruz failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable. Moreover, alibi is inherently weak and easily fabricated.

3. On the qualifying circumstance of “with homicide.”

The Court held that the homicide was committed on the occasion of the robbery, making it a single, indivisible crime of Robbery with Homicide. The killing was directly linked to the robbery, as it occurred when the victim resisted the unlawful taking. Thus, the trial court correctly appreciated the qualifying circumstance.

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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.