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

Ponente: J. PERFECTO

FACTS

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, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and forcibly took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos resisted, and a struggle ensued, resulting in the accused stabbing the victim, causing his death.

The prosecution presented eyewitness Maria Santos, the victim’s wife, who testified that she saw the accused enter their house, demand money, and stab her husband when he refused to comply. The police recovered a blood-stained knife at the scene, which was positively identified by Maria. The defense, however, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering at the time of the incident. The accused also denied ownership of the knife.

The Regional Trial Court (RTC) found the accused 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 be given credence over the positive identification by the eyewitness.
3. Whether the aggravating circumstance of dwelling was properly appreciated.

RULING

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

The Supreme Court affirmed the conviction. The positive identification by eyewitness Maria Santos was clear, consistent, and credible. She had a direct view of the incident, knew the accused prior to the crime, and never wavered in her testimony. The defense failed to impute any ill motive on her part to falsely testify. The recovery of the blood-stained knife at the scene, though not conclusively linked to the accused by forensic evidence, corroborated her account of a stabbing.

The defense of alibi was correctly rejected. 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. The accused failed to establish physical impossibility, as the location of his alibi was merely a few hours away by vehicle. Alibi is inherently weak and cannot prevail over positive identification.

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

As held in numerous jurisprudence, alibi is the weakest defense, especially when contradicted by a credible eyewitness who had no reason to falsely accuse the appellant. The Court found no reason to depart from the factual findings of the RTC and CA, which are accorded great respect, especially on matters of witness credibility.

3. The aggravating circumstance of dwelling was correctly appreciated.

The crime was committed in the victim’s own house, which is an aggravating circumstance under Article 14 of the Revised Penal Code. The accused deliberately entered the sanctum of the victim’s home to commit robbery, which increased the victim’s vulnerability and the gravity of the offense. This aggravating circumstance was properly alleged in the Information and proven during trial.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the Regional Trial Court’s judgment finding accused-appellant JUAN DELA CRUZ guilty beyond reasonable doubt of 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.