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, 2018, 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 of valuables.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. Several relatives corroborated his alibi.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The RTC gave more weight 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 credence.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide based on the eyewitness testimony and in rejecting his defense of alibi.

RULING

NO, the Court of Appeals did not err. The Supreme Court AFFIRMED the conviction.

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RATIONALE

The Supreme Court held:

1. Positive Identification Over Alibi The eyewitness, Maria Reyes, gave a clear, consistent, and credible account of the incident. She positively identified Dela Cruz as the perpetrator, whom she knew personally even before the crime. The defense of alibi is inherently weak and cannot prevail over positive identification, especially when the accused is known to the witness. 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 prove physical impossibility, as the city where he claimed to be was only a few hours away by vehicle.

2. Elements of Robbery with Homicide All elements were proven:
– Taking of personal property The eyewitness saw Dela Cruz carrying a bag of valuables belonging to the victim as he fled.
– With intent to gain The unlawful taking established animus lucrandi.
– With violence or intimidation The use of a knife and the killing of the victim constituted violence.
– Homicide as a result of or on occasion of the robbery The killing was intimately connected to the robbery, as it occurred when the victim resisted.

3. Credibility of Witness The trial court’s assessment of witness credibility is entitled to great respect, as it had the opportunity to observe the witness’s demeanor. No ill motive was shown for the witness to falsely testify against Dela Cruz.

4. Conspiracy Not applicable, as only one accused was involved.

5. Penalty Robbery with Homicide under Article 294(1) of the Revised Penal Code is punishable by reclusion perpetua to death. With no aggravating or mitigating circumstances, the penalty of reclusion perpetua was correctly imposed.

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DISPOSITIVE PORTION

WHEREFORE, the petition is DENIED. The Decision of the Court of Appeals affirming the 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.