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

Ponente: J. PERFECTO

FACTS

Accused-appellant Juan Dela Cruz was charged with the crime of Robbery with Homicide under Article 294(1) 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 was stabbed multiple times, resulting in his death.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The police recovered the knife, which bore Dela Cruz’s fingerprints, and some of the stolen items were found in his possession.

The defense interposed alibi and denial, claiming Dela Cruz was in a different city attending a family gathering at the time of the incident. He argued that the evidence against him was fabricated.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua without eligibility for parole. 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 aggravating circumstance of dwelling was properly appreciated.
3. Whether the penalty imposed is correct.

RULING

1. On the proof of guilt beyond reasonable doubt YES.

The Court affirmed the findings of the lower courts. The positive identification by eyewitness Maria Reyes, who had no motive to falsely testify, was clear and credible. Her testimony was corroborated by physical evidence: the knife with Dela Cruz’s fingerprints and the stolen items found in his possession. The defense of alibi and denial cannot prevail over positive identification and concrete evidence. Alibi is inherently weak and must be supported by credible corroboration, which was absent here.

2. On the aggravating circumstance of dwelling NO.

The Court held that the aggravating circumstance of dwelling under Article 14(3) of the Revised Penal Code cannot be appreciated in this case. For dwelling to be considered, it must be proven that the accused deliberately sought the seclusion and privacy of the victim’s home to facilitate the commission of the crime. Here, the information and evidence did not establish that the robbery was planned to take advantage of the isolation of the dwelling. The mere fact that the crime occurred inside a house is insufficient; the prosecution must show that the accused specifically chose the location because it was a dwelling. This was not proven beyond reasonable doubt.

3. On the penalty MODIFIED.

Robbery with Homicide under Article 294(1) is punishable by reclusion perpetua to death. With the disallowance of the aggravating circumstance of dwelling, and with no other aggravating or mitigating circumstances, the indivisible penalty of reclusion perpetua is properly imposed. However, the RTC and CA erred in adding “without eligibility for parole.” Under the Revised Penal Code, as amended by Republic Act No. 9346, the penalty for crimes punishable by reclusion perpetua shall be served without the benefit of parole under the Indeterminate Sentence Law, but the phrase “without eligibility for parole” is a term under the Dangerous Drugs Act and is not applicable to crimes under the Revised Penal Code like Robbery with Homicide. The proper penalty is reclusion perpetua.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is PARTIALLY GRANTED. 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 suffer the penalty of RECLUSION PERPETUA. He is ordered to pay the heirs of Pedro Santos ₱75,000 as civil indemnity, ₱75,000 as moral damages, ₱75,000 as exemplary damages, and ₱50,000 as temperate damages, all with legal interest at 6% per annum from the finality of this judgment until fully paid.

SO ORDERED.