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 enter their house, demand money, and stab her husband when he resisted. The defense, however, interposed the defense of alibi, claiming that the accused was in Bulacan, 50 kilometers away, attending a family reunion at the time of the incident. The accused presented his sister and a cousin to corroborate his alibi.

The Regional Trial Court (RTC) of Quezon City found the accused guilty beyond reasonable doubt, giving full credence to the eyewitness testimony and rejecting the alibi. The RTC 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 should be given credence over the positive identification by the eyewitness.
3. Whether the penalty and damages imposed are proper.

RULING

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

The Supreme Court held that the positive identification of the accused by the eyewitness, Maria Santos, prevails over the defense of alibi. Maria Santos had a clear and unobstructed view of the accused during the incident, as the crime occurred inside her well-lit home, and she had known the accused as a neighbor for several years prior. Her testimony was consistent, straightforward, and credible.

The Court emphasized that alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness. For alibi to prosper, the accused must prove not only that he was somewhere else when the crime was committed but also that it was physically impossible for him to have been at the scene of the crime. Here, Bulacan is only 50 kilometers from Quezon City, and travel between the two locations is possible within a few hours. Thus, it was not physically impossible for the accused to have been at the crime scene.

2. The defense of alibi cannot overcome the positive identification by the eyewitness.

The Court reiterated the well-established doctrine that positive testimony outweighs negative testimony. The defense of alibi is inherently suspect because it is easily fabricated and difficult to disprove. In contrast, Maria Santos’s testimony was corroborated by the physical evidence and the nature of the wounds sustained by the victim, which were consistent with her account.

3. The penalty and damages imposed are proper, with modifications.

The crime of Robbery with Homicide is punishable by reclusion perpetua to death. Since no aggravating or mitigating circumstances were proven, the penalty of reclusion perpetua was correctly imposed by the lower courts.

However, the Supreme Court modified the damages in line with recent jurisprudence. The Court increased the awards to conform to current standards:

– Civil indemnity: ₱100,000
– Moral damages: ₱100,000
– Exemplary damages: ₱100,000
– Temperate damages: ₱50,000 (in lieu of actual damages, since the exact amount of stolen cash/jewelry was not fully substantiated)
– Interest: 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 award of damages as follows:

Accused-appellant is ordered to pay the heirs of Pedro Santos:

1. ₱100,000 as civil indemnity;
2. ₱100,000 as moral damages;
3. ₱100,000 as exemplary damages;
4. ₱50,000 as temperate damages; and
5. Interest at the rate of 6% per annum on all damages awarded from the finality of this judgment until fully paid.

Costs against accused-appellant.

SO ORDERED.