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 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 can prevail over positive identification.
3. Whether the qualifying circumstance of use of a deadly weapon was properly appreciated.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Court ruled in the affirmative. The prosecution successfully established all the elements of Robbery with Homicide: (a) the taking of personal property with intent to gain; (b) the taking was with violence or intimidation against a person; (c) the robbery resulted in homicide. The testimony of Maria Santos was clear, consistent, and credible. She had a direct view of the incident and had no ill motive to falsely testify against the accused. Her positive identification prevails over the denial and alibi of the accused.

2. On the defense of alibi versus positive identification.

The defense of 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 place where he claimed to be was only a few hours away by public transportation, making it possible for him to be at the crime scene.

3. On the qualifying circumstance of use of a deadly weapon.

The use of a deadly weapon (a knife) was duly proven and properly appreciated as an aggravating circumstance. The knife was used to inflict the fatal wounds, and its use was integral to the commission of the robbery and homicide. This qualifies the crime to Robbery with Homicide under Article 294(1) of the Revised Penal Code, punishable by reclusion perpetua to death. In the absence of any mitigating circumstance, the penalty of reclusion perpetua was correctly imposed.

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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.