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, 2018, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, presented an alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the crime. The trial court found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua.

On appeal, Dela Cruz argued that the prosecution failed to prove his guilt beyond reasonable doubt, citing inconsistencies in the eyewitness’s testimony and the weakness of the evidence linking him to the crime.

ISSUE

Whether the trial court erred in convicting accused-appellant Juan Dela Cruz of Robbery with Homicide despite alleged inconsistencies in the prosecution’s evidence and the defense of alibi.

RULING

NO. The Supreme Court AFFIRMED the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide.

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DOCTRINE

1. Alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible eyewitness.
2. Inconsistencies in minor details do not impair the credibility of a witness, especially when the core testimony remains consistent and credible.
3. Robbery with Homicide is a composite crime where the homicide is committed by reason or on the occasion of the robbery. Proof of the robbery and the killing, along with the intent to rob, suffices for conviction.

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RATIONALE

1. Credibility of Eyewitness Testimony
The Court held that the eyewitness, Maria Reyes, positively identified Dela Cruz as the perpetrator. Her testimony was clear, consistent, and credible. Minor inconsistencies in her statements—such as the exact time of the incident or the color of Dela Cruz’s clothing—do not undermine her overall credibility. The Court emphasized that trivial discrepancies are normal in honest testimonies and may even indicate truthfulness.

2. Weakness of Alibi
Dela Cruz’s alibi was rejected for being inherently weak. For an alibi to prosper, the accused must prove not only that he was elsewhere at the time of the crime but also that it was physically impossible for him to be at the crime scene. Dela Cruz failed to establish this impossibility. Moreover, alibi cannot prevail over positive identification by a credible witness.

3. Elements of Robbery with Homicide
The prosecution proved all elements of the crime:
– Robbery was established through testimony that cash and jewelry were taken.
– Homicide was proven by the victim’s death due to stab wounds.
– The killing occurred by reason or on the occasion of the robbery, as shown by the sequence of events.

4. Moral Certainty of Guilt
The totality of evidence—eyewitness testimony, circumstantial evidence (bloodied knife, flight), and the weak alibi—led to a moral certainty of Dela Cruz’s guilt. The trial court’s findings on credibility are entitled to great respect, absent any arbitrariness.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court convicting accused-appellant Juan Dela Cruz of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.