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, 2010, 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. Cash and jewelry were taken.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene of the crime. 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 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 the positive identification by an eyewitness.
3. Whether the qualifying circumstance of homicide was properly appreciated in convicting the accused of Robbery with Homicide.

RULING

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

The Court held that the positive identification of the accused by eyewitness Maria Reyes was clear, consistent, and credible. She had no motive to falsely testify against the accused. Her testimony was corroborated by physical evidence and the dying declaration of the victim, who identified Dela Cruz as his assailant before succumbing to his injuries.

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

The defense of alibi is inherently weak and must be supported by credible corroboration. Dela Cruz failed to present sufficient evidence to prove that it was physically impossible for him to be at the crime scene. The distance between the fiesta location and the crime scene was not so great as to preclude his presence at the latter. Hence, alibi must yield to the positive identification by the prosecution witness.

3. The qualifying circumstance of homicide was properly appreciated.

Robbery with Homicide is a special complex crime where the homicide may be either intentional or incidental to the robbery. The prosecution established that the killing occurred by reason or on the occasion of the robbery. The taking of personal property was proven, and the homicide was a direct consequence of the robbery. Thus, all elements of the crime were present.

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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 reclusion perpetua is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.