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 of the Revised Penal Code. The prosecution alleged that on January 15, 2010, in Quezon City, Dela Cruz, armed with a knife, entered the house 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 Santos, the victim’s wife, who testified that she saw Dela Cruz, whom she knew personally as a neighbor, inside their house holding a knife and fleeing after the incident. The police recovered the stolen items from Dela Cruz’s possession upon arrest.

The defense interposed alibi and denial. Dela Cruz claimed he was in a different city attending a fiesta during the time of the incident. He alleged that the stolen items were planted by the police.

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 and denial can prevail over positive identification.
3. Whether the penalty imposed is correct.

RULING

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

The Court held that the prosecution successfully established all elements of Robbery with Homicide:
– Taking of personal property proven by the testimony of Maria Santos and recovery of stolen items.
– With intent to gain evident from the unlawful taking.
– With violence or intimidation against persons the use of a knife and the killing of Pedro Santos.
– Homicide committed by reason or on occasion of the robbery the killing occurred during the commission of the robbery.

The positive identification by Maria Santos, who knew Dela Cruz personally, was clear, consistent, and credible. The defense failed to show any ill motive for her to falsely testify.

2. On alibi and denial NO, they cannot prevail over positive identification.

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. Dela Cruz failed to prove this physical impossibility. Moreover, denial is an intrinsically weak defense and cannot prevail over the positive testimony of a credible witness.

3. On the penalty YES, reclusion perpetua is proper.

Under Article 294 of the Revised Penal Code, when homicide is committed by reason or on occasion of the robbery, the penalty is reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the lower penalty of reclusion perpetua was correctly imposed.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.