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 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 room was well-lit. She claimed she knew the accused as a former neighbor. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in Bulacan attending a fiesta at the time of the incident, which was about 50 kilometers away.

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.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused based on the eyewitness identification, 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 the accused.

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RATIONALE

1. Credibility of Eyewitness Testimony
The Court held that the eyewitness identification by Maria Santos was credible and reliable. She had a clear view of the accused, whom she recognized as a former neighbor, and her testimony remained consistent on material points throughout the trial. Minor inconsistencies regarding peripheral details do not affect the credibility of a witness, especially when the core testimony of witnessing the crime is steadfast.

2. Defense of Alibi
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 have been at the crime scene. The distance of 50 kilometers between Bulacan and Quezon City did not render it impossible for the accused to have traveled to the crime scene, given the availability of transportation.

3. Elements of Robbery with Homicide
All elements of Robbery with Homicide were established:
a) The taking of personal property with intent to gain;
b) The taking was accomplished with violence or intimidation against a person;
c) The robbery resulted in homicide.
The prosecution proved that the accused took cash and jewelry and, in the process, killed the victim.

4. Treachery and Abuse of Superior Strength
The Court noted that the attack was sudden and unexpected, rendering the victim defenseless, which qualifies the killing as attended by treachery. This aggravating circumstance was properly appreciated by the lower courts.

5. Penalty
Under Article 294 of the Revised Penal Code, Robbery with Homicide is punishable by reclusion perpetua to death. Since no aggravating or mitigating circumstances were sufficiently proven to modify the penalty, the imposition of reclusion perpetua by the lower courts was correct.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. 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.

Costs against accused-appellant.

SO ORDERED.