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, giving full credence to the eyewitness identification 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 heirs of the victim. 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 eyewitness identification of the accused was reliable and sufficient to sustain a conviction.
2. Whether the defense of alibi should have been given credence.
3. Whether the crime committed was properly qualified as Robbery with Homicide.

RULING

1. On the reliability of the eyewitness identification:
The Supreme Court found the eyewitness identification unreliable. The witness, Maria Santos, claimed she recognized the accused because the room was well-lit, but the prosecution failed to establish the sufficiency of lighting and the opportunity for a clear view. No evidence was presented on the distance between the witness and the accused, the duration of the observation, or the presence of obstructions. The Court emphasized that identification must be positive, categorical, and consistent, and any doubt as to its accuracy must be resolved in favor of the accused. Here, the identification was vague and uncorroborated.

2. On the defense of alibi:
While alibi is generally a weak defense, it gains strength when the prosecution’s evidence is weak. In this case, since the eyewitness identification was fraught with doubt, the alibi supported by the testimony of the accused and a barangay official regarding his presence in Bulacan created reasonable doubt. The distance of 50 kilometers was not insurmountable, but the prosecution failed to prove that it was physically impossible for the accused to be at the crime scene.

3. On the proper crime committed:
The Court found that the prosecution failed to prove the essential elements of Robbery with Homicide—specifically, that the killing was committed by reason or on occasion of the robbery. The evidence did not clearly establish that the robbery preceded the killing or that the killing was necessary to carry out the robbery. The sequence and causal link were not proven beyond reasonable doubt. At most, the evidence might support separate crimes of robbery and homicide, but not the special complex crime.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is GRANTED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of Juan dela Cruz for Robbery with Homicide is REVERSED and SET ASIDE. Accused-appellant Juan dela Cruz is ACQUITTED on the ground of reasonable doubt. The Director of the Bureau of Corrections is ordered to IMMEDIATELY RELEASE the accused from custody unless he is being held for another lawful cause. Let an entry of final judgment be issued immediately.

SO ORDERED.