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, 2010, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw Dela Cruz, whom she knew personally, stab her husband. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in Bulacan at the time of the incident, attending a family gathering. The defense presented two witnesses to corroborate his alibi.

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 despite the defense of alibi and alleged inconsistencies in the prosecution’s evidence.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of accused-appellant Juan Dela Cruz.

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RATIONALE:

1. Alibi is inherently weak and cannot prevail over positive identification.
The Court reiterated the settled doctrine that alibi is one of the weakest defenses, especially when the accused is positively identified by a credible witness. In this case, Maria Santos gave a clear, consistent, and categorical testimony that she saw Dela Cruz stab her husband. Her identification was not only based on familiarity (she knew Dela Cruz as a neighbor) but was also corroborated by physical evidence and the sequence of events. 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 Bulacan is not so far from Quezon City as to preclude his presence at the crime scene.

2. Inconsistencies in the testimony of the eyewitness are minor and do not affect credibility.
The defense pointed out alleged inconsistencies in Maria Santos’s testimony regarding the time of the incident and the exact positioning of the accused. The Court held that these inconsistencies pertained to minor details and did not detract from the core of her testimony—that she saw Dela Cruz commit the crime. In fact, minor inconsistencies may even strengthen credibility, as they indicate that the witness was not rehearsed.

3. The crime committed is Robbery with Homicide.
The elements of Robbery with Homicide are present: (a) the taking of personal property with intent to gain; (b) the taking was with violence or intimidation against a person; and (c) on the occasion of the robbery, homicide was committed. The prosecution proved that Dela Cruz took cash and jewelry from the victim’s house and, on the same occasion, killed the victim. The homicide is regarded as one special complex crime with robbery, and the penalty is indivisible.

4. Penalty and Damages.
The penalty for Robbery with Homicide under Article 294 of the Revised Penal Code is reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the lower courts correctly imposed reclusion perpetua. The Court also affirmed the award of civil indemnity, moral damages, and exemplary damages to the heirs of the victim, in line with prevailing jurisprudence.

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DISPOSITIVE PORTION:

WHEREFORE, the appeal is DENIED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

SO ORDERED.