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, 2015, 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 eyewitness testimony from Maria Santos, the victim’s wife, who positively identified Dela Cruz as the perpetrator. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in a different city at the time of the incident.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC’s decision in toto. Hence, this appeal.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide based on the prosecution’s evidence.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide.

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RATIONALE

The Court held that all the elements of Robbery with Homicide were sufficiently proven by the prosecution:

1. The taking of personal property with intent to gain The prosecution established that cash and jewelry were taken from the victim’s residence.
2. The taking was with violence or intimidation against persons The accused was armed with a knife and used force to subdue the victim.
3. The robbery resulted in homicide The victim’s death was a direct consequence of the robbery, as the fatal stabbing occurred during the struggle.

The Court gave full credence to the positive identification made by eyewitness Maria Santos, who had a clear view of the accused during the incident. Her testimony was consistent, straightforward, and unwavering on cross-examination. The Court emphasized that positive identification prevails over alibi, especially when the alibi is not physically impossible and is not corroborated by credible witnesses.

Furthermore, the defense of alibi must demonstrate that the accused was so far away that it was impossible for him to have been at the scene of the crime. Dela Cruz failed to meet this burden, as the distance between his alleged location and the crime scene was not insurmountable.

The Court also noted that the trial court’s assessment of witness credibility is entitled to great respect, as it had the opportunity to observe the witnesses’ demeanor firsthand. No compelling reason was shown to overturn such findings.

Finally, the Court modified the damages awarded in accordance with prevailing jurisprudence, increasing the civil indemnity, moral damages, and exemplary damages to P100,000.00 each, and awarding actual damages as proven, plus interest at the legal rate.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is AFFIRMED with MODIFICATION as to the awards of damages. Accused-appellant is sentenced to suffer the penalty of reclusion perpetua and ordered to pay the heirs of the victim:

1. Civil indemnity P100,000.00;
2. Moral damages P100,000.00;
3. Exemplary damages P100,000.00;
4. Actual damages P50,000.00; and
5. Interest at 6% per annum on all damages from finality of judgment until fully paid.

Costs against accused-appellant.

SO ORDERED.