G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. PERFECTO

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, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused enter their house, demand money, and stab her husband when he resisted. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering at the time of the incident.

The Regional Trial Court (RTC) found the accused 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 can prevail over the positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated.

RULING

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

The Court held that the positive identification of the accused by eyewitness Maria Santos was clear, consistent, and credible. She had no ill motive to falsely testify against the accused. Her testimony was corroborated by physical evidence and the dying declaration of the victim, who identified the accused as his assailant before succumbing to his injuries.

2. The defense of alibi cannot prevail over positive identification.

The defense of 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 elsewhere when the crime was committed but also that it was physically impossible for him to be at the crime scene. The accused failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable.

3. The qualifying circumstance of homicide was properly appreciated.

Robbery with Homicide is a special complex crime where the homicide may be either intentional or incidental. The prosecution established that the killing occurred by reason or on the occasion of the robbery. The fact that the victim was stabbed when he resisted the robbery sufficiently proves the nexus between the robbery and the homicide.

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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 the crime of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.