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

Ponente: J. PERFECTO

FACTS

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, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and recognized him because the room was well-lit. She also testified that she heard the accused demand money from her husband before stabbing him. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering at the time of the incident. The trial court convicted the accused, giving full credence to the eyewitness testimony and rejecting the alibi. The accused appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the trial court erred in convicting the accused of Robbery with Homicide based on the eyewitness identification, despite the defense of alibi and alleged inconsistencies in the prosecution’s evidence.

RULING

The Supreme Court AFFIRMED the conviction but MODIFIED the penalty and damages.

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RATIONALE

1. Credibility of Eyewitness Testimony
The Court upheld the trial court’s assessment of the eyewitness’s credibility. The witness, Maria Santos, had a clear and unobstructed view of the accused, whom she knew prior to the incident. Her positive identification prevailed over the defense of alibi, which was not corroborated by strong evidence of physical impossibility for the accused to be at the crime scene. Jurisprudence consistently holds that positive identification, when categorical and consistent, outweighs alibi.

2. Elements of Robbery with Homicide
The Court found all elements present:
a) Taking of personal property Cash and jewelry were stolen.
b) With intent to gain The accused’s demand for money established animus lucrandi.
c) With violence or intimidation The use of a knife and the stabbing constituted violence.
d) Homicide committed on the occasion of the robbery The killing was directly linked to the robbery, as it occurred during the commission of the crime.

3. Defense of Alibi
The defense failed to prove that it was physically impossible for the accused to be at the crime scene. The distance between the crime scene and the place where the accused claimed to be was not insurmountable, and no credible witnesses corroborated his presence elsewhere at the exact time of the crime.

4. Penalty and Damages
The Court modified the penalty. Under Article 294 of the Revised Penal Code, Robbery with Homicide is punishable by reclusion perpetua to death. Since no aggravating or mitigating circumstances were proven, the penalty imposed was reclusion perpetua, in accordance with prevailing jurisprudence. The Court also increased the awards for civil indemnity, moral damages, and exemplary damages to ₱100,000 each, and actual damages were awarded based on receipts presented.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court 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 the following amounts:
– ₱100,000 as civil indemnity;
– ₱100,000 as moral damages;
– ₱100,000 as exemplary damages; and
– ₱50,000 as actual damages.

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

SO ORDERED.