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, in Quezon City, Dela Cruz, armed with a knife, entered the residence 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 recognized as a former neighbor, stab her husband. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in Bulacan, 50 kilometers away, at the time of the incident, attending a family gathering. Several relatives testified to corroborate his alibi.

The Regional Trial Court (RTC) convicted Dela Cruz, giving full credence to the eyewitness identification and rejecting the alibi. The Court of Appeals (CA) affirmed the RTC decision. Hence, this appeal.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant based on the eyewitness identification, despite the defense of alibi supported by corroborating witnesses.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide.

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DOCTRINE

1. Alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible eyewitness. 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.
2. Positive identification, when categorical, consistent, and without ill motive, prevails over alibi and denial.
3. Flight is an indication of guilt. The accused’s failure to surrender immediately and his attempt to evade arrest corroborate the finding of guilt.

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RATIO DECIDENDI

1. Weakness of Alibi: The defense failed to establish the physical impossibility for Dela Cruz to have been at the crime scene. Bulacan is merely 50 kilometers from Quezon City and accessible by various means of transportation within a few hours. The alibi, even if corroborated by relatives, cannot overcome positive identification.

2. Credibility of Eyewitness: Maria Santos gave a clear, consistent, and straightforward account. She had known Dela Cruz for years as a former neighbor, making her identification reliable. No ill motive was shown for her to falsely testify against the accused.

3. Flight as Evidence of Guilt: Records show that Dela Cruz went into hiding for several months after the incident and was only arrested in a different province. This conduct is inconsistent with innocence and bolsters the prosecution’s case.

4. Elements of Robbery with Homicide Proven: All elements were established: (a) taking of personal property with intent to gain, (b) with violence or intimidation against persons, (c) homicide committed on the occasion or by reason of the robbery. The killing was integral to the robbery, as the victim resisted the taking.

5. Affirmation of Lower Courts’ Findings: The trial court’s assessment of witness credibility is entitled to great respect, as it had the opportunity to observe the witnesses firsthand. No compelling reason was shown to overturn these findings.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.