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 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’s decision in toto. Hence, this appeal before the Supreme Court.

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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 homicide was properly appreciated in the crime of robbery.

RULING

1. On the proof of guilt beyond reasonable doubt:
The Supreme Court held that the prosecution successfully established the guilt of the accused beyond reasonable doubt. The eyewitness testimony of Maria Santos was clear, consistent, and credible. She had a direct view of the incident and positively identified Dela Cruz, whom she knew prior to the crime. The Court emphasized that positive identification, when categorical and consistent, prevails over alibi and denial.

2. On the defense of alibi:
The defense of alibi must be 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. 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 cannot prevail over positive identification.

3. On the qualifying circumstance of homicide in robbery:
The Court affirmed that the killing occurred by reason or on the occasion of the robbery. The evidence showed that the homicide was directly linked to the robbery, as the stabbing transpired during the struggle when the victim resisted the taking of his property. Thus, the crime was properly classified as Robbery with Homicide under Article 294(1) of the Revised Penal Code.

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DISPOSITIVE PORTION:

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the 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.