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 forcibly took cash and jewelry. During the robbery, Pedro Santos resisted, and in the ensuing struggle, the accused stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused enter their house, demand money, and stab her husband when he refused to comply. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering 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.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused for Robbery with Homicide despite the alleged weakness of the prosecution’s evidence and the strength of the accused’s defense of alibi.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of the accused for Robbery with Homicide.

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RATIONALE

1. Credibility of Prosecution Witness. The Court upheld the findings of the lower courts regarding the credibility of Maria Santos. Her positive identification of the accused was clear, consistent, and unwavering. The Court emphasized that positive identification prevails over alibi, especially when the witness had no ill motive to falsely testify against the accused.

2. Defense of Alibi. The defense of alibi must be supported by clear and convincing evidence that the accused was so far away that it was physically impossible for him to be at the scene of the crime. In this case, the accused failed to prove the impossibility of his presence at the crime scene. The place where he claimed to be was not so distant as to preclude his presence at the locus criminis.

3. Elements of Robbery with Homicide. All elements of the crime were proven beyond reasonable doubt:
– Taking of personal property belonging to another (cash and jewelry were taken);
– With intent to gain (animus lucrandi);
– With violence or intimidation against persons (the accused was armed and used force);
– Homicide was committed as a consequence or on the occasion of the robbery (the killing of Pedro Santos was directly linked to the robbery).

4. Treachery (Alevosia). The Court also noted that the attack was sudden and unexpected, without giving the victim any opportunity to defend himself, qualifying the killing with treachery. This, however, is absorbed in the special complex crime of Robbery with Homicide.

5. Penalty. 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, in accordance with prevailing jurisprudence and the prohibition of the death penalty under Republic Act No. 9346.

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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.

Costs against accused-appellant.

SO ORDERED.