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 forcibly took cash and jewelry. During the robbery, Pedro Santos resisted, and in the ensuing struggle, the accused stabbed him, causing 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 refused to comply. 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 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 can prevail over the positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated in the crime of robbery.

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 eyewitness Maria Santos was clear, categorical, and consistent. She had a direct and unobstructed view of the accused during the incident, and there was no evidence of any ill motive on her part to falsely testify against him. The Court emphasized that positive identification, when credible and categorical, prevails over alibi and denial.

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 have been at the scene of the crime. In this case, the accused merely claimed to be in a different city, which is not an insurmountable distance. The Court ruled that for alibi to prosper, the accused must demonstrate not only that he was elsewhere when the crime was committed but also that it was physically impossible for him to have been at the crime scene. This, the accused failed to do.

3. The qualifying circumstance of homicide was properly appreciated.

The Court affirmed that the killing occurred by reason or on occasion of the robbery. The evidence showed a direct causal connection between the robbery and the homicide—the stabbing transpired when the victim resisted the unlawful taking. Thus, the crime committed is the special complex crime of Robbery with Homicide under Article 294 of the Revised Penal Code, where homicide is treated as a qualifying circumstance, resulting in a single indivisible penalty.

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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 suffer the penalty of reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.