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, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the commission of 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 account and rejecting the defense of 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.

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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 proper.

RULING

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

The Court upheld the findings of the lower courts. The positive identification of the accused by eyewitness Maria Reyes, who had no motive to falsely testify, was clear and categorical. Her testimony remained consistent on cross-examination and was corroborated by physical evidence and the autopsy report. The defense failed to show any ill motive on her part.

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

The Court reiterated the well-established doctrine 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. Dela Cruz failed to prove the element of physical impossibility, as the location of the family gathering was not so far as to preclude his presence at the crime scene.

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

The Court affirmed the awards for civil indemnity and moral damages. However, following recent jurisprudence, the Court increased the amounts to Php 75,000.00 each for civil indemnity and moral damages. Exemplary damages in the amount of Php 75,000.00 are also awarded due to the presence of the qualifying aggravating circumstance of dwelling. Temperate damages of Php 50,000.00 are awarded in lieu of actual damages, as the prosecution proved the fact of loss but not its exact amount. All monetary awards shall earn legal interest at 6% per annum from the finality of this decision 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 the crime of Robbery with Homicide is AFFIRMED with MODIFICATION in the award of damages. Accused-appellant is sentenced to suffer the penalty of reclusion perpetua and ordered to pay the heirs of Pedro Santos the following amounts:

1. Civil Indemnity Php 75,000.00;
2. Moral Damages Php 75,000.00;
3. Exemplary Damages Php 75,000.00;
4. Temperate Damages Php 50,000.00.

All monetary awards shall earn legal interest at the rate of six percent (6%) per annum from the finality of this judgment until fully paid.

SO ORDERED.