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 commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented eyewitness testimony from Maria Santos, the victim’s wife, who 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 should prevail over the positive identification by the eyewitness.
3. Whether the qualifying circumstance of use of a deadly weapon was properly appreciated.

RULING

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

The Court held that 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 testimony of eyewitness Maria Santos was found to be credible, consistent, and categorical. She positively identified Dela Cruz as the person who entered their house, demanded money, and stabbed her husband when he resisted. Her testimony was corroborated by physical evidence, including the stolen items recovered from Dela Cruz’s possession and the medico-legal report confirming the fatal stab wound.

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 elsewhere when the crime was committed but also that it was physically impossible for him to be at the crime scene. Dela Cruz failed to establish physical impossibility. The distance between his alleged location and the crime scene was not so considerable as to preclude his presence at the latter.

Moreover, Maria Santos had sufficient opportunity to identify Dela Cruz, as the crime occurred in their well-lit living room, and she had known him prior to the incident as a neighbor.

3. The qualifying circumstance of use of a deadly weapon was properly appreciated.

The use of a knife, a deadly weapon, was integral to the commission of the crime. It was used to intimidate the victim and to inflict the fatal wound when the victim resisted. This circumstance is inherent in the crime of Robbery with Homicide and was duly proven by the prosecution.

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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 suffer the penalty of reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.