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 inside their house and recognized him because the room was well-lit. She also testified that she heard the accused demand money from her husband before stabbing him.

The defense interposed the defense of alibi, claiming that the accused was in a different city attending a family reunion at the time of the incident. The accused presented his aunt and cousin to corroborate his alibi.

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 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 should prevail over the positive identification by the eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated to convict the accused of Robbery with Homicide.

RULING

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

The Supreme Court held that the positive identification of the accused by the eyewitness, Maria Santos, was credible and reliable. The Court emphasized that positive identification, when categorical and consistent, prevails over alibi and denial. Maria Santos had a clear view of the accused, whom she knew prior to the incident, and her testimony remained unwavering even during cross-examination.

The Court also noted that the defense failed to prove that it was physically impossible for the accused to be at the crime scene. The distance between the place of the alleged alibi and the crime scene was not so great as to preclude the accused’s presence at the latter.

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

The defense of alibi is inherently weak and must be supported by clear and convincing evidence that the accused could not have been physically present at the crime scene. In this case, the accused’s alibi was not airtight. The testimonies of his relatives were deemed insufficient to establish physical impossibility. Moreover, alibi becomes even less credible when there is no ill motive on the part of the eyewitness to falsely testify against the accused.

3. The qualifying circumstance of homicide was properly appreciated.

For Robbery with Homicide, the killing must be a consequence of or have a direct connection to the robbery. The prosecution established that the homicide occurred by reason or on the occasion of the robbery. The demand for money and the subsequent stabbing when the victim resisted formed a continuous sequence of events. Thus, the complex crime of Robbery with Homicide was correctly applied.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan Dela Cruz for the crime of Robbery with Homicide and sentencing him to suffer the penalty of reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.