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

Ponente: J. Reyes

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 January 15, 2018, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw Dela Cruz, whom she recognized as a former neighbor, fleeing their house immediately after she heard her husband’s shouts. She also testified that she found her husband bloodied and the family’s cash and jewelry missing.

The defense interposed alibi, claiming Dela Cruz was in a different city attending a fiesta at the time of the incident. He presented a barangay official and friends to corroborate his presence at the fiesta.

The Regional Trial Court (RTC) found Dela Cruz 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.

Dela Cruz appealed to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond reasonable doubt, that his alibi was credible, and that the identification by the eyewitness was unreliable.

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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 Supreme Court held that the positive identification by eyewitness Maria Santos was credible and sufficient to establish Dela Cruz’s guilt. The Court emphasized that positive identification, when categorical and consistent, prevails over alibi and denial. Maria Santos knew Dela Cruz as a former neighbor and had no ill motive to falsely testify against him. Her testimony was straightforward and remained unshaken during cross-examination.

The elements of Robbery with Homicide were all present:
– Taking of personal property cash and jewelry were stolen.
– With intent to gain inherent in the act of robbery.
– With violence or intimidation the accused was armed with a knife.
– Homicide was committed the victim died from stab wounds.
– Homicide was committed by reason or on occasion of the robbery the killing occurred during the robbery as the victim resisted.

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

The Court reiterated the doctrine that alibi is inherently weak and must be supported by clear and convincing evidence of physical impossibility for the accused to be at the crime scene. Dela Cruz’s claim of being in a different city was not physically impossible, as the distance could be traversed by vehicle within hours. The testimony of his witnesses was deemed insufficient to overcome the positive identification by the eyewitness.

3. The award of damages is modified in accordance with prevailing jurisprudence.

The Supreme Court sustained the awards for civil indemnity and moral damages but increased the exemplary damages in line with recent rulings to deter similar crimes. The Court also awarded temperate damages for the stolen property, as its exact value could not be proven with certainty, and actual damages for funeral expenses supported by receipts.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is AFFIRMED with MODIFICATION. Accused-appellant is sentenced to reclusion perpetua and 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
– Actual Damages ₱25,000 (supported by receipts)

All monetary awards shall earn legal interest at 6% per annum from the finality of this decision until fully paid.

SO ORDERED.