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, with intent to rob. During the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented an eyewitness, Maria Reyes, a neighbor who claimed to have seen Dela Cruz fleeing the scene.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. Several relatives testified to corroborate his presence elsewhere.

The Regional Trial Court (RTC) found Dela Cruz 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 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 an eyewitness.
3. Whether the award of damages is in accordance with prevailing jurisprudence.

RULING

1. On the Proof of Guilt Beyond Reasonable Doubt

The Court AFFIRMED the conviction. The prosecution successfully established all the elements of Robbery with Homicide:
– Taking of personal property belonging to another (cash and jewelry were stolen from the victim’s house).
– With intent to gain (animus lucrandi).
– With violence or intimidation against persons.
– Homicide was committed by reason or on the occasion of the robbery.

The positive and categorical identification by eyewitness Maria Reyes, who had no ill motive to testify falsely, prevailed over the weak defense of alibi. Her testimony was consistent and remained unshaken during cross-examination. The trial court’s assessment of witness credibility is entitled to great respect, as it had the direct opportunity to observe their demeanor.

2. On the Defense of Alibi

The defense of alibi must fail. Jurisprudence consistently holds that alibi is one of the weakest defenses, easily fabricated, 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 have been at the crime scene. Dela Cruz failed to prove the physical impossibility, as the location of the family gathering was still within Metro Manila and accessible within a few hours.

3. On the Award of Damages

The Court MODIFIED the awards for damages in line with current jurisprudence (People v. Jugueta). The awards are as follows:
– Civil Indemnity: ₱100,000.00
– Moral Damages: ₱100,000.00
– Exemplary Damages: ₱100,000.00
– Temperate Damages: ₱50,000.00 (in lieu of actual damages, as no receipts were presented for funeral expenses, but such expenses are indubitably incurred)
– All monetary awards shall earn legal interest at 6% per annum from the finality of this judgment until fully paid.

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DISPOSITIVE PORTION:

WHEREFORE, the Decision of the Court of Appeals is AFFIRMED with MODIFICATION as to the awards of damages. Accused-appellant Juan Dela Cruz is found GUILTY beyond reasonable doubt of the crime of Robbery with Homicide and is sentenced to suffer the penalty of Reclusion Perpetua. He is 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 ₱50,000.00 as Temperate Damages. All monetary awards shall earn legal interest at six percent (6%) per annum from the finality of this judgment until fully paid.

SO ORDERED.