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, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz enter the victim’s house and later flee carrying a bag. The police recovered a blood-stained knife near the crime scene, which was positively identified by Reyes as similar to the one used by Dela Cruz. Dela Cruz interposed the defense of alibi, claiming he was in a different city attending a festival 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.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should be given credence over positive identification.
3. Whether the aggravating circumstance of dwelling was properly appreciated.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.

The Court held that the positive identification by eyewitness Maria Reyes was credible, consistent, and unwavering. Her testimony was corroborated by physical evidence, particularly the blood-stained knife recovered near the scene. The defense failed to impute any ill motive on the part of Reyes to falsely testify against Dela Cruz.

2. The defense of alibi 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 the impossibility of his presence at the locus criminis. Moreover, alibi crumbles in the face of positive identification by a credible witness.

3. The aggravating circumstance of dwelling was correctly appreciated.

Robbery with homicide is a special complex crime under Article 294 of the Revised Penal Code. The aggravating circumstance of dwelling is inherent when the robbery is committed in the victim’s house, as in this case. This aggravating circumstance was properly considered by the lower courts in imposing the penalty.

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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 and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.