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, and took cash and jewelry. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene of the crime. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. The trial court convicted Dela Cruz, giving credence to the eyewitness testimony and rejecting the alibi. The court sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim.

Dela Cruz appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the trial court erred in disregarding his alibi.

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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 in light of the positive identification by the eyewitness.

RULING

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

The Supreme Court affirmed the conviction. The Court held that the positive identification by eyewitness Maria Reyes, who had no ill motive to testify falsely against the accused, prevailed over the defense of alibi. Reyes testified in a clear, categorical, and consistent manner, and her testimony was corroborated by physical evidence and the dying declaration of the victim.

The Court emphasized that for the defense of 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 establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable within the timeframe of the crime.

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

The Court reiterated the well-settled doctrine that alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness. The trial court correctly found the eyewitness testimony to be credible and reliable. The defense failed to show any reason why the witness would falsely accuse Dela Cruz.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court convicting accused-appellant Juan Dela Cruz of the crime of Robbery with Homicide and sentencing him to suffer the penalty of reclusion perpetua is AFFIRMED with MODIFICATION. Accused-appellant is ordered to pay the heirs of Pedro Santos the following amounts:

Civil Indemnity ₱75,000.00;
Moral Damages ₱75,000.00;
Exemplary Damages ₱75,000.00; and
Interest at the rate of six percent (6%) per annum on all damages awarded from the date of finality of this judgment until fully paid.

Costs against accused-appellant.

SO ORDERED.