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 based on the evidence presented.

RULING

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

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RATIONALE

1. Credibility of Eyewitness Testimony
The Court held that the testimony of eyewitness Maria Reyes was credible and consistent on material points. Minor inconsistencies in her statements did not affect her overall reliability, as they pertained to trivial details that did not undermine the core of her account—that she saw Dela Cruz fleeing the crime scene with a bloodied knife. The trial court’s assessment of witness credibility is entitled to great respect, as it had the opportunity to observe the witness’s demeanor firsthand.

2. Weakness of Alibi
The defense of alibi is inherently weak and cannot prevail over positive identification by a credible witness. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime occurred but also that it was physically impossible for him to have been at the crime scene. Dela Cruz failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable within the timeframe of the incident.

3. Elements of Robbery with Homicide
The Court found all elements of Robbery with Homicide present:
– Robbery was committed by taking personal property with intent to gain.
– Homicide was committed on the occasion of the robbery.
– The homicide was perpetrated by reason or on the occasion of the robbery.
The prosecution proved that Dela Cruz took cash and jewelry from Santos’s residence and killed him when he resisted.

4. Conspiracy and Intent
Although Dela Cruz acted alone, the crime of Robbery with Homicide does not require conspiracy. The single act of killing during the robbery suffices to hold the perpetrator liable for the special complex crime.

5. Penalty
The penalty for Robbery with Homicide under Article 294 of the Revised Penal Code is reclusion perpetua to death. In the absence of aggravating or mitigating circumstances, the trial court correctly imposed reclusion perpetua, consistent with prevailing jurisprudence and the prohibition of the death penalty under Republic Act No. 9346 .

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court of Quezon City, Branch 90, finding accused-appellant Juan Dela Cruz GUILTY of Robbery with Homicide and sentencing him to reclusion perpetua, is AFFIRMED in toto.

Costs against accused-appellant.

SO ORDERED.