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 claimed she knew the accused as a former neighbor. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in Bulacan attending a fiesta at the time of the incident, which was about 50 kilometers away.

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.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused based on the eyewitness identification, despite the defense of alibi and alleged inconsistencies in the prosecution’s evidence.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of the accused.

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RATIONALE

1. Credibility of Eyewitness Testimony
The Court held that the eyewitness identification by Maria Santos was credible and reliable. She had a clear view of the accused, whom she recognized as a former neighbor, and her testimony remained consistent on material points throughout the trial. Minor inconsistencies in her statements regarding peripheral details did not affect her credibility but instead indicated that her testimony was not rehearsed.

2. Weakness of Alibi
The defense of alibi 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 distance of 50 kilometers between Bulacan and Quezon City did not make it impossible for the accused to travel to the crime scene. Hence, the defense of alibi must fail.

3. Elements of Robbery with Homicide
The crime of Robbery with Homicide requires: (a) the taking of personal property with violence or intimidation; (b) the property belongs to another; (c) the taking is done with animo lucrandi; and (d) on the occasion of the robbery, homicide is committed. All these elements were proven beyond reasonable doubt. The robbery was established by the taking of cash and jewelry, and the homicide was proven by the fatal stabbing of Pedro Santos during the commission of the robbery.

4. Treachery and Abuse of Superior Strength
The Court noted that the attack was sudden and unexpected, rendering the victim defenseless. The accused used a knife and attacked the victim from behind, ensuring the execution of the crime without risk to himself. This constituted treachery, which qualified the killing to murder. However, since the charge was Robbery with Homicide, treachery is absorbed as an aggravating circumstance.

5. Penalty
Under Article 294 of the Revised Penal Code, Robbery with Homicide is punishable by reclusion perpetua to death. In the absence of aggravating or mitigating circumstances, the penalty of reclusion perpetua was correctly imposed by the lower courts.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. The Decision of the Court of Appeals affirming the conviction of Juan dela Cruz for the crime of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto.

Costs against the accused-appellant.

SO ORDERED.