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

Ponente: J. PERFECTO

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, Maria Santos, and forcibly took her jewelry and cash. During the robbery, Dela Cruz stabbed Santos, causing her death.

The prosecution presented an eyewitness, Pedro Reyes, who testified that he saw Dela Cruz fleeing the scene of the crime carrying a bag and a bloodied knife. The police later arrested Dela Cruz and recovered the stolen items and the alleged murder weapon in his possession. Dela Cruz interposed the defense of alibi, claiming he was in a different city 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 by an eyewitness.
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 affirmed the findings of the lower courts. The positive identification of the accused by eyewitness Pedro Reyes, who had no motive to falsely testify, was clear and categorical. Reyes’ testimony was consistent on material points and withstood rigorous cross-examination. The Court has consistently held that positive identification, when credible and categorical, prevails over alibi and denial.

Furthermore, the corpus delicti of the crime was established through the testimony of the eyewitness, the autopsy report confirming the fatal stab wounds, and the recovery of the stolen items and the knife from the accused. The chain of custody of the evidence was properly established.

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

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. Dela Cruz failed to meet this burden. His claimed location was not so geographically remote as to make his presence at the crime scene impossible. Alibi is inherently weak and easily fabricated.

3. The aggravating circumstance of dwelling was correctly appreciated.

The crime was committed in the victim’s own home, which is a sanctum of privacy and security. The invasion of the dwelling added a degree of perversity and moral shock to the crime. The aggravating circumstance of dwelling is inherent in the special complex crime of Robbery with Homicide when the robbery is committed inside a house, as in this case. This does not alter the penalty, which is already reclusion perpetua to death, but it was properly considered in the imposition of the indivisible penalty.

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DISPOSITIVE PORTION

WHEREFORE, the Decision of the Court of Appeals is AFFIRMED. Accused-appellant JUAN DELA CRUZ is found GUILTY beyond reasonable doubt of the crime of Robbery with Homicide and is sentenced to suffer the penalty of reclusion perpetua, with all the accessory penalties provided by law. He is ordered to pay the heirs of Maria Santos civil indemnity, moral damages, exemplary damages, and temperate damages, all with legal interest until fully paid.

SO ORDERED.