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

Ponente: J. Reyes

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, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death. The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene with a bag and a bloodied knife.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different barangay attending a fiesta at the time of the incident. The defense presented several witnesses to corroborate his presence at the fiesta.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The RTC gave more credence to the positive identification by the eyewitness over the defense of alibi. The Court of Appeals (CA) affirmed the RTC decision in toto.

Dela Cruz appealed to the Supreme Court via a petition for review on certiorari, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the defense of alibi should have been given weight.

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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 prevail over the positive identification by an eyewitness.

RULING

1. On the proof of guilt beyond reasonable doubt YES.

The Supreme Court held that the prosecution successfully established all the elements of Robbery with Homicide:

– Taking of personal property The eyewitness saw Dela Cruz fleeing with a bag belonging to the victim.
– With intent to gain The taking was unlawful and for personal gain.
– With violence or intimidation The accused was armed with a knife.
– Homicide was committed The victim died from stab wounds inflicted during the robbery.

The Court emphasized that the positive identification by the eyewitness, who had no ill motive to testify falsely, was clear and categorical. Her testimony remained consistent even under cross-examination.

2. On the defense of alibi NO.

The defense of alibi is inherently weak and cannot prevail over the positive identification of the accused. 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 crime scene. Here, the fiesta was in a neighboring barangay, which was only 30 minutes away by vehicle. Thus, it was not physically impossible for Dela Cruz to have been at the crime scene.

Moreover, alibi becomes even less credible when there is no corroboration by disinterested witnesses. The defense witnesses were mostly friends and relatives, whose testimonies lacked impartiality.

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DOCTRINE

– Positive identification prevails over alibi. When the accused is positively identified by a credible witness, the defense of alibi must fail, especially when it is not physically impossible for the accused to have been at the crime scene.
– Elements of Robbery with Homicide: (1) the taking of personal property with intent to gain; (2) with violence or intimidation against a person; (3) the homicide is committed either by reason or on occasion of the robbery.

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DISPOSITIVE

WHEREFORE, the petition is DENIED. The Decision of the Court of Appeals affirming the conviction of Juan Dela Cruz for Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED. Costs against accused-appellant.

SO ORDERED.