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, 2015, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the robbery, Dela Cruz stabbed Santos, causing his death, and took cash and jewelry.

The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene of the crime. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city at the time of the incident. The trial court convicted Dela Cruz, sentencing him to reclusion perpetua and ordering him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim.

Dela Cruz appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the trial court erred in giving credence to the testimony of the eyewitness.

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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 be given credence over the positive identification by an eyewitness.

RULING

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

The Supreme Court affirmed the conviction. The Court held that the testimony of eyewitness Maria Reyes was credible, consistent, and positively identified Dela Cruz as the perpetrator. The Court emphasized that positive identification, when categorical and consistent, prevails over alibi and denial. The defense failed to show that it was physically impossible for Dela Cruz to be at the crime scene.

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

The Court reiterated the doctrine that alibi is inherently weak and must be supported by clear and convincing evidence. Dela Cruz failed to prove that he was so far away that he could not have been at the locus criminis at the time of the incident. Moreover, alibi becomes even weaker in the face of positive identification by a credible witness.

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DOCTRINE

– Positive identification by a credible witness prevails over alibi and denial. Alibi must be supported by clear and convincing evidence showing the physical impossibility of the accused’s presence at the crime scene.
– In robbery with homicide, the prosecution must prove the elements of robbery and the killing, whether intentional or accidental, as a result or on the occasion of the robbery.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court convicting accused-appellant Juan Dela Cruz of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED. Accused-appellant is ordered to pay the heirs of Pedro Santos civil indemnity, moral damages, and exemplary damages, with interest at the legal rate of six percent (6%) per annum from the finality of this judgment until fully paid.

SO ORDERED.