G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. Reyes

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, 2015, Dela Cruz, armed with a knife, entered the house of the victim, Maria Santos, and took her jewelry and cash. During the robbery, Santos resisted, and Dela Cruz stabbed her, causing her death.

The prosecution presented an eyewitness, Pedro Gomez, who testified that he saw Dela Cruz fleeing from Santos’s house with a bloodied knife. The police recovered the stolen items from Dela Cruz’s possession upon arrest. Dela Cruz interposed the defense of alibi, claiming he was in a different barangay at the time of the incident. The trial court found him 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 lack of direct evidence linking him to the homicide.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for Robbery with Homicide despite alleged inconsistencies in the prosecution’s evidence and the defense of alibi.

RULING

NO, the Court of Appeals did not err. The conviction is affirmed.

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RATIONALE

1. Credibility of Eyewitness Testimony
– The alleged inconsistencies in Pedro Gomez’s testimony pertained to minor details (e.g., the exact time of the incident, the color of Dela Cruz’s shirt) and did not affect the core of his account—that he saw Dela Cruz flee from the crime scene with a bloodied knife. Jurisprudence holds that minor inconsistencies may even enhance a witness’s credibility by showing that their testimony was not rehearsed.
– Gomez’s positive identification of Dela Cruz prevailed over the latter’s denial and alibi. The defense failed to show that it was physically impossible for Dela Cruz to be at the crime scene.

2. Elements of Robbery with Homicide
– The prosecution established all elements:
a) Robbery was proven by the taking of jewelry and cash from Santos’s house through force upon things (breaking into the house).
b) Homicide was proven by Santos’s death resulting from the stabbing during the robbery.
c) The homicide was committed by reason or on occasion of the robbery, as the killing occurred when Santos resisted the taking of her property.
– The recovery of stolen items from Dela Cruz’s possession, coupled with the eyewitness account, formed an unbroken chain of circumstantial evidence leading to his guilt.

3. Defense of Alibi
– Alibi is inherently weak and must be supported by clear and convincing evidence that the accused could not have been at the crime scene. Dela Cruz merely claimed he was in a neighboring barangay, which was not geographically impossible to traverse within the timeframe. Without proof of physical impossibility, alibi cannot prevail over positive identification.

4. Treachery and Aggravating Circumstances
– The trial court correctly appreciated treachery because the attack on Santos was sudden and without warning, leaving her defenseless. However, since Robbery with Homicide is a special complex crime, treachery is absorbed and does not alter the penalty.

5. Penalty
– Under Article 294 of the Revised Penal Code, Robbery with Homicide is punishable by reclusion perpetua to death. With no aggravating or mitigating circumstances, the penalty of reclusion perpetua was correctly imposed. Civil indemnity, moral damages, and exemplary damages awarded by the lower court were also affirmed in line with prevailing jurisprudence.

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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 Robbery with Homicide is AFFIRMED in toto. Costs against accused-appellant.

SO ORDERED.