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 the incident. She also identified the stolen items recovered from Dela Cruz’s possession upon his arrest.

The defense interposed alibi and denial. Dela Cruz claimed he was in a different city attending a fiesta at the time of the crime. He asserted that the stolen items were planted by the police, and the identification by Maria Santos was mistaken due to poor lighting and her distraught state.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua without eligibility for parole, 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.

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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 can prevail over positive identification.
3. Whether the penalty and damages imposed are proper.

RULING

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

The Court affirmed the findings of the lower courts. The positive identification by eyewitness Maria Santos, who knew Dela Cruz prior to the incident, was clear, consistent, and credible. Her testimony detailed how she saw Dela Cruz inside their house and fleeing immediately after the stabbing. The recovery of the stolen items from Dela Cruz further corroborated his guilt. The defense failed to show any ill motive on the part of the witness to falsely testify.

The Court reiterated the doctrine that alibi and denial are inherently weak defenses 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 elsewhere when the crime occurred but also that it was physically impossible for him to be at the crime scene. Dela Cruz failed to establish physical impossibility, as the fiesta he attended was in a nearby city, still accessible within a reasonable travel time.

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

The Court held that the positive, categorical, and consistent testimony of the prosecution witness, corroborated by physical evidence, prevails over the unsubstantiated claims of alibi and denial. The assessment of witness credibility by the trial court is accorded great respect, as it had the opportunity to observe the witness’s demeanor firsthand. No compelling reason was shown to overturn such assessment.

3. The penalty and damages imposed are proper.

Robbery with Homicide under Article 294(1) of the Revised Penal Code is punishable by reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the penalty of reclusion perpetua was correctly imposed. Following prevailing jurisprudence, the Court affirmed the award of civil indemnity, moral damages, and exemplary damages. Additionally, the Court imposed interest at the rate of six percent (6%) per annum on all monetary awards from the date of finality of this judgment until fully paid.

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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 the crime of Robbery with Homicide is AFFIRMED with MODIFICATION. Accused-appellant is sentenced to suffer the penalty of reclusion perpetua without eligibility for parole and ordered to pay the heirs of Pedro Santos the following amounts:

₱100,000.00 as civil indemnity;
₱100,000.00 as moral damages;
₱100,000.00 as exemplary damages; and
Interest at the rate of six percent (6%) per annum on all damages awarded from the date of finality of this judgment until fully paid.

Costs against accused-appellant.

SO ORDERED.