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, 2015, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the robbery, Santos was stabbed multiple times, resulting in his death. Several pieces of jewelry and cash were taken.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw Dela Cruz inside their house during the incident. She identified him in open court. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a fiesta at the time of the crime.

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 can prevail over the positive identification by an eyewitness.

RULING

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

The Court held that all elements of Robbery with Homicide were established:
– Taking of personal property belonging to another proven by the missing jewelry and cash.
– With intent to gain (animus lucrandi) inferred from the unlawful taking.
– With violence or intimidation against persons the attack on Pedro Santos.
– Homicide was committed as a consequence or on the occasion of the robbery the stabbing occurred during the robbery.

The positive identification by Maria Santos, who had no ill motive to falsely testify, was clear, categorical, and consistent. Her testimony was given full credence by both the RTC and CA, and the Supreme Court found no reason to deviate from their factual findings, especially on matters of witness credibility.

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 was so far away that it was physically impossible for him to be at the crime scene. Dela Cruz failed to prove this physical impossibility. The place where he claimed to be was only a few hours away by vehicle from the crime scene. Moreover, alibi crumbles in the face of positive identification by a credible witness.

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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.