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 robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented an eyewitness, Maria Reyes, a neighbor who claimed to have seen Dela Cruz fleeing the scene.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. Several relatives testified to corroborate his presence elsewhere.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt, giving full credence to the eyewitness testimony and rejecting the alibi. The RTC sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to the victim’s heirs. The Court of Appeals (CA) affirmed the RTC decision in toto.

Dela Cruz now appeals before the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the lower courts erred in disregarding his alibi.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should be given credence in light of the positive identification by an eyewitness.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Supreme Court AFFIRMED the conviction.

The Court held that the prosecution successfully established all the elements of Robbery with Homicide:
– Taking of personal property belonging to another;
– With intent to gain (animus lucrandi);
– With violence or intimidation against persons;
– Property is taken on the occasion or by reason of the robbery; and
– Homicide was committed as a consequence or on the occasion of the robbery.

The eyewitness, Maria Reyes, gave a clear, consistent, and credible account of seeing Dela Cruz, whom she knew personally, fleeing the victim’s house immediately after hearing shouts. Her testimony remained unshaken during cross-examination. The defense failed to show any ill motive on her part to falsely testify against the accused.

2. On the defense of alibi.

The Court REJECTED the defense of alibi.

The Court reiterated the well-established 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.

Here, Dela Cruz claimed to be in a different city, but the distance was only approximately 50 kilometers, travelable by vehicle within an hour. Thus, it was not physically impossible for him to have been at the crime scene. The testimonies of his relatives, being naturally biased, could not overcome the positive identification by the eyewitness.

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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 is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.