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, 2015, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and recognized him because the light was on. She also testified that she heard her husband shouting for help before he was killed. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a fiesta at the time of the incident.

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 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 the positive identification by an eyewitness.
3. Whether the penalty imposed is proper.

RULING

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

The Supreme Court held that the positive identification of the accused by the eyewitness, Maria Santos, was credible and sufficient to establish his guilt. The Court noted that the witness had a clear view of the accused, there was adequate lighting, and she had no ill motive to falsely testify against him. The defense failed to show any reason why the witness would lie.

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 somewhere else when the crime was committed but also that it was physically impossible for him to have been at the scene of the crime. The accused failed to establish physical impossibility, as the place where he claimed to be was not so far as to preclude his presence at the crime scene.

3. The penalty imposed is proper.

Robbery with Homicide under Article 294(1) of the Revised Penal Code is punishable by reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the penalty of reclusion perpetua was correctly imposed by the lower courts. The Court also affirmed the award of civil indemnity, moral damages, and exemplary damages to the heirs of the victim.

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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.

SO ORDERED.