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(1) of the Revised Penal Code. The prosecution alleged that on January 15, 2010, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the robbery, Dela Cruz stabbed Santos, causing his death, and took cash and jewelry.

The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene of the crime carrying a bag. The police recovered the stolen items from Dela Cruz’s possession two days later. Dela Cruz interposed the defense of alibi, claiming he was in a different city at the time of the crime.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal.

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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 positive identification.
3. Whether the qualifying circumstance of homicide was properly appreciated.

RULING

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

The Court held that the prosecution successfully established all elements of Robbery with Homicide:
– Taking of personal property belonging to another proven by the recovery of stolen items from the accused.
– With intent to gain inferred from the unlawful taking.
– With violence or intimidation the use of a knife and the killing of the victim.
– Homicide committed on the occasion or by reason of the robbery the killing was integral to the robbery, as the victim resisted.

The positive identification by eyewitness Maria Reyes, who had no ill motive to testify falsely, prevailed over the accused’s denial and alibi.

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

Alibi is inherently weak and must be supported by clear and convincing evidence of physical impossibility for the accused to be at the crime scene. Dela Cruz failed to prove it was physically impossible for him to be at the victim’s house at the time of the crime. Positive identification by a credible witness trumps alibi.

3. The qualifying circumstance of homicide was properly appreciated.

The killing was committed by reason or on the occasion of the robbery, as the evidence showed that the homicide was perpetrated to facilitate the robbery or to escape. Thus, the crime was properly classified as Robbery with Homicide, not as separate crimes of robbery and homicide.

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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 Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED. Costs against accused-appellant.

SO ORDERED.