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 claimed she knew the accused as a former neighbor. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in Bulacan attending a fiesta at the time of the incident, supported by the testimonies of his relatives.

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 victim’s heirs. 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 prevail over the positive identification by the eyewitness.
3. Whether the award of damages is proper.

RULING

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

The Court held that the positive identification by the eyewitness, Maria Santos, was credible and sufficient to establish the accused’s guilt. She testified clearly and consistently, without any ill motive to falsely testify against the accused. Her familiarity with the accused as a former neighbor bolstered her identification. The defense failed to impeach her credibility or show any reason why she would fabricate her testimony.

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

The defense of alibi is inherently weak and must be supported by clear and convincing evidence that the accused was so far away that it was physically impossible for him to be at the scene of the crime. In this case, Bulacan is not so distant from Quezon City as to preclude the accused’s presence at the crime scene. Alibi cannot prevail over the positive, categorical, and consistent identification by an eyewitness.

3. The award of damages is proper but must be modified in accordance with prevailing jurisprudence.

The Court affirmed the awards of civil indemnity and moral damages but increased the same to ₱75,000 each. Exemplary damages of ₱75,000 were also awarded due to the presence of the qualifying aggravating circumstance of dwelling. Actual damages were not awarded due to lack of receipts, but temperate damages of ₱50,000 were granted in lieu thereof. All monetary awards shall earn interest at 6% per annum from finality until fully paid.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. 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 reclusion perpetua. He is ordered to pay the heirs of Pedro Santos the following amounts:

– Civil indemnity: ₱75,000
– Moral damages: ₱75,000
– Exemplary damages: ₱75,000
– Temperate damages: ₱50,000

All monetary awards shall earn interest at 6% per annum from finality until fully paid.

SO ORDERED.