G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. PERFECTO

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, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family reunion at the time of the incident. The trial court found the prosecution’s evidence credible and convicted Dela Cruz, sentencing him to reclusion perpetua and ordering him to pay civil indemnity, moral damages, and exemplary damages to the victim’s heirs.

Dela Cruz appealed, arguing that the trial court erred in giving credence to the lone eyewitness and 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 over the positive identification by an eyewitness.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.

The Court held that the positive identification by eyewitness Maria Reyes was clear, consistent, and credible. She had no motive to falsely testify against the accused. Her testimony was corroborated by physical evidence, including the recovery of the stolen items in Dela Cruz’s possession and the murder weapon with his fingerprints. The defense failed to impeach her credibility or show any ill motive.

2. The defense of alibi cannot prevail over positive identification.

The Court reiterated the well-established doctrine that alibi is the weakest defense and 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 crime scene. Dela Cruz’s claim of being in a different city was not substantiated by credible witnesses or documentary evidence. Moreover, the distance between the two locations was not so great as to preclude his presence at the crime scene.

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DOCTRINE

– Positive identification by a credible witness prevails over alibi. Alibi must be supported by proof of the physical impossibility of the accused’s presence at the locus criminis.
– In robbery with homicide, the prosecution must prove: (a) the taking of personal property with intent to gain; (b) the use of violence or intimidation; and (c) the killing of a person on the occasion or by reason of the robbery.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court, Branch 90, Quezon City, finding accused-appellant Juan Dela Cruz GUILTY of Robbery with Homicide and sentencing him to reclusion perpetua, is AFFIRMED with MODIFICATION. Accused-appellant is ordered to pay the heirs of Pedro Santos the following amounts:
– ₱100,000 as civil indemnity;
– ₱100,000 as moral damages;
– ₱100,000 as exemplary damages; and
– ₱50,000 as temperate damages.

All monetary awards shall earn interest at the rate of six percent (6%) per annum from the finality of this Decision until fully paid.

SO ORDERED.