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 room was well-lit. She also testified that she heard her husband shouting the accused’s name during the struggle. 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 should be given credence over the positive identification by the eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated to convict the accused of Robbery with Homicide.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Supreme Court AFFIRMED the conviction. The Court held that the prosecution successfully established the guilt of the accused beyond reasonable doubt through the positive and categorical testimony of eyewitness Maria Santos. Her testimony was clear, consistent, and credible. She had no ill motive to falsely testify against the accused. The Court emphasized that positive identification, when credible and categorical, prevails over alibi and denial.

2. On the defense of alibi.

The defense of alibi was rejected. 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. Moreover, alibi is inherently weak and cannot prevail over positive identification.

3. On the qualifying circumstance of homicide.

The Court ruled that homicide was a necessary consequence of the robbery, as the killing was done to facilitate the robbery or to escape. The elements of Robbery with Homicide were present: (a) the taking of personal property with violence or intimidation; (b) the property belonged to another; (c) the taking was done with animus lucrandi; and (d) on the occasion of the robbery, homicide was committed. The killing need not precede the robbery; it is enough that the homicide was committed by reason or on the occasion of the robbery.

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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 is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.