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

Ponente: J. PERFECTO

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 the evening of January 15, 2015, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented eyewitness testimony from Maria Santos, the victim’s wife, who identified Dela Cruz as the perpetrator. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering 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.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide based on the prosecution’s evidence.

RULING

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

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RATIONALE

The Supreme Court held that all elements of Robbery with Homicide were proven beyond reasonable doubt:

1. The taking of personal property with intent to gain The prosecution established that cash and jewelry were taken from the victim’s residence.
2. The taking was with violence or intimidation against persons The accused was armed with a knife and used violence to consummate the robbery.
3. The robbery resulted in homicide The killing of Pedro Santos was a direct consequence of the robbery, as it occurred during the commission thereof or on the occasion of the robbery.

The Court gave full credence to the positive identification made by eyewitness Maria Santos, who had a clear view of the accused during the incident. Her testimony was found to be consistent, straightforward, and credible. The defense of alibi was rejected as it could not prevail over the positive identification of the accused. For alibi to prosper, the accused must prove 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 scene of the crime. Dela Cruz failed to prove such physical impossibility.

Furthermore, the Court ruled that the qualifying circumstance of dwelling was correctly appreciated. The crime was committed in the victim’s own house, which is an aggravating circumstance under Article 294 of the Revised Penal Code. However, since the penalty for Robbery with Homicide is already reclusion perpetua to death, the aggravating circumstance of dwelling does not alter the penalty but was properly considered in the imposition of the maximum period of the indeterminate penalty.

The Court also addressed the civil liability of the accused. It modified the award of damages, increasing the indemnity for death to Php 100,000.00, awarding moral damages of Php 100,000.00, and exemplary damages of Php 100,000.00, in line with prevailing jurisprudence. Actual damages were deleted for lack of sufficient evidence, but temperate damages of Php 50,000.00 were awarded instead. All monetary awards shall earn legal interest at 6% per annum from the finality of judgment until fully paid.

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DISPOSITIVE PORTION

WHEREFORE, the Decision of the Court of Appeals is AFFIRMED with MODIFICATION. Accused-appellant Juan Dela Cruz is found GUILTY beyond reasonable doubt of Robbery with Homicide and is sentenced to suffer the penalty of Reclusion Perpetua. He is ordered to pay the heirs of Pedro Santos the following amounts:
1. Php 100,000.00 as civil indemnity;
2. Php 100,000.00 as moral damages;
3. Php 100,000.00 as exemplary damages;
4. Php 50,000.00 as temperate damages; and
5. Interest at 6% per annum on all damages awarded from the finality of this judgment until fully paid.

Costs against accused-appellant.

SO ORDERED.