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

Ponente: J. REYES, J.

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, 2010, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the commission of the robbery, Dela Cruz stabbed Santos, causing his death. 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.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for Robbery with Homicide despite the alleged weakness of the prosecution’s evidence and the strength of his defense of alibi.

RULING

The appeal is without merit. The conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is affirmed.

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RATIONALE

The Supreme Court held that the prosecution successfully proved the guilt of the accused beyond reasonable doubt. The elements of Robbery with Homicide are: (1) the taking of personal property with intent to gain; (2) the taking was with violence or intimidation against persons; and (3) on the occasion of the robbery, homicide was committed. All these elements were established through the credible testimony of eyewitness Maria Santos, who gave a clear and consistent account of the incident. Her positive identification of Dela Cruz prevailed over his defense of alibi.

The Court reiterated the well-settled doctrine that alibi is inherently weak and cannot prevail over positive identification 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 the crime scene and his alleged location was not insurmountable within the time frame of the crime.

Moreover, the trial court’s assessment of witness credibility is entitled to great weight and respect, as it had the opportunity to observe the witnesses’ demeanor and conduct during trial. No compelling reason was shown to deviate from the factual findings of both the RTC and the CA.

The Court also found that the qualifying circumstance of dwelling was duly alleged and proven, justifying the imposition of reclusion perpetua. The crime was committed in the victim’s house, which added to the seriousness of the offense.

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DISPOSITIVE PORTION

WHEREFORE, the Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is AFFIRMED. Costs against accused-appellant.

SO ORDERED.