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.

—

ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi can prevail over the positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated to convict the accused of Robbery with Homicide.

RULING

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

The Supreme Court held that the positive and categorical testimony of eyewitness Maria Santos, who had no ill motive to falsely testify against the accused, was credible and sufficient to establish the accused’s guilt. Her testimony was consistent and withstood rigorous cross-examination. The Court emphasized that positive identification prevails over alibi, especially when the witness had a clear view of the perpetrator and there was no evidence of improper motive.

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

The defense of alibi is inherently weak 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. In this case, the accused failed to prove the impossibility of his presence at the locus criminis. The family gathering he attended was in a neighboring city, which did not preclude his ability to travel to Quezon City to commit the crime. Thus, the defense of alibi must fail.

3. The qualifying circumstance of homicide was properly appreciated.

For Robbery with Homicide to be convicted, it is sufficient that the homicide be committed by reason or on the occasion of the robbery. The prosecution established that the killing of Pedro Santos occurred during the commission of the robbery, as the stabbing was done to overcome the victim’s resistance and facilitate the taking of his property. The Court found that the elements of Robbery with Homicide were all present:
– Taking of personal property with violence or intimidation;
– Property belongs to another;
– Unlawful taking with intent to gain; and
– Homicide was committed on the occasion or by reason of the robbery.

—

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. Costs against accused-appellant.

SO ORDERED.