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, 2018, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the robbery, Dela Cruz stabbed Santos, causing his death, and took cash and jewelry amounting to ₱50,000.00.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw Dela Cruz stab her husband and flee with their belongings. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident.

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 before the Supreme Court.

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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 penalty imposed is proper.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.
The Supreme Court held that the positive identification by eyewitness Maria Santos was credible, consistent, and categorical. She had a clear view of the incident and had no ill motive to falsely testify against the accused. The Court emphasized that positive identification, when credible, prevails over alibi and denial.

2. The defense of alibi cannot prevail over positive identification.
For alibi to prosper, the accused must prove not only that he was elsewhere when the crime was committed but also that it was physically impossible for him to be at the crime scene. Dela Cruz failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable. Thus, his alibi must fail.

3. The penalty imposed is proper.
Robbery with Homicide under Article 294 is punishable by reclusion perpetua to death. In the absence of aggravating or mitigating circumstances, the penalty of reclusion perpetua was correctly imposed by the lower courts. The Court also affirmed the award of civil indemnity, moral damages, and exemplary damages to the heirs of the victim.

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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 in toto. Costs against accused-appellant.

SO ORDERED.