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

Ponente: J. PERFECTO

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, 2018, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and recognized him because the room was well-lit. She also testified that she heard her husband shouting the accused’s name during the struggle.

The defense interposed alibi and denial. The accused claimed he was in a different city attending a fiesta at the time of the incident, supported by the testimonies of his friend and a barangay official.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt, sentenced him to reclusion perpetua, and ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim. The Court of Appeals (CA) affirmed the RTC decision in toto.

Hence, this appeal before the Supreme Court.

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ISSUES
1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi and denial should prevail over the positive identification by the eyewitness.
3. Whether the penalty and damages imposed are proper.

RULING

1. On the proof of guilt beyond reasonable doubt YES.

The Supreme Court held that the positive identification by the eyewitness, Maria Santos, who had no ill motive to falsely testify, prevails over the defense of alibi and denial. Her testimony was clear, consistent, and credible. She had a good opportunity to see the accused because of sufficient lighting and proximity. The defense failed to show that it was physically impossible for the accused to be at the crime scene.

2. On alibi and denial vs. positive identification NO, the defense cannot prevail.

Alibi is inherently weak and must be supported by clear and convincing evidence that the accused could not have been at the scene of the crime at the time of its commission. Here, the accused failed to prove the physical impossibility of his presence. Denial, like alibi, is an intrinsically weak defense and cannot prevail over positive identification.

3. On the penalty and damages MODIFIED.

The crime of Robbery with Homicide under Article 294(1) of the Revised Penal Code is punishable by reclusion perpetua to death. Since no aggravating or mitigating circumstances attended the commission, the penalty of reclusion perpetua was correctly imposed.

However, the Court modified the awards for damages in line with recent jurisprudence. The awards are as follows:

– Civil indemnity: ₱100,000
– Moral damages: ₱100,000
– Exemplary damages: ₱100,000
– Temperate damages (in lieu of actual damages, since the exact amount taken was not fully proven): ₱50,000
– Interest at 6% per annum on all damages from finality of judgment until fully paid.

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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 with MODIFICATION in the awards of damages as stated above.

SO ORDERED.