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. Dela Cruz was arrested shortly after the incident, and the stolen items were recovered from him.

During trial, the prosecution presented eyewitness testimony from Maria Reyes, a neighbor who claimed to have seen Dela Cruz fleeing the scene. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in a different barangay attending a fiesta at the time of the crime. The defense presented several witnesses to corroborate his alibi.

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.

Hence, this appeal before the Supreme Court.

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ISSUES

1. Whether the defense of alibi can prevail over the positive identification of the accused by an eyewitness.
2. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.

RULING

1. NO, the defense of alibi cannot prevail over positive identification.
The Supreme Court reiterated the well-established doctrine that alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness. 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 scene of the crime. In this case, Dela Cruz failed to prove physical impossibility, as the barangay where he claimed to be was only 30 minutes away from the crime scene. Moreover, the eyewitness, Maria Reyes, gave a clear, consistent, and credible account of seeing Dela Cruz flee from the victim’s house immediately after the crime. Her testimony was corroborated by the recovery of stolen items from the accused.

2. YES, the prosecution proved guilt beyond reasonable doubt.
All elements of Robbery with Homicide were established: (a) the taking of personal property with intent to gain; (b) with violence or intimidation against a person; (c) the robbery resulted in homicide. The eyewitness testimony, coupled with the physical evidence (recovered stolen items and the murder weapon with Dela Cruz’s fingerprints), constituted an unbroken chain of evidence leading to the conclusion that Dela Cruz was the perpetrator. The defense failed to cast any reasonable doubt on the prosecution’s evidence.

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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 is AFFIRMED. Costs against accused-appellant.

SO ORDERED.