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, 2010, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. 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 with Santos’s wallet.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a fiesta at the time of the incident. The trial court found the prosecution’s evidence credible and convicted Dela Cruz, sentencing him to reclusion perpetua without eligibility for parole. The court also ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim.

Dela Cruz appealed, arguing that the trial court erred in giving credence to the eyewitness identification and in disregarding his alibi.

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ISSUES

1. Whether the eyewitness identification of the accused was reliable and sufficient to support a conviction.
2. Whether the defense of alibi should prevail over the positive identification by the prosecution witness.
3. Whether the penalty imposed and the damages awarded are in accordance with law and jurisprudence.

RULING

1. On the reliability of the eyewitness identification:
The Court found the eyewitness identification reliable. Maria Reyes had a clear view of the incident, as the crime occurred in a well-lit area, and she was familiar with Dela Cruz, having seen him in the neighborhood prior to the incident. The Court emphasized that positive identification, when categorical and consistent, prevails over alibi and denial. The witness’s testimony remained unwavering even under cross-examination.

2. On the defense of alibi:
The defense of alibi must fail. For alibi to prosper, the accused must prove not only that he was elsewhere when the crime was committed but also that it was physically impossible for him to have been at the crime scene. Dela Cruz failed to establish physical impossibility, as the distance between the fiesta location and the crime scene could be traversed within a few hours. Alibi is inherently weak and cannot prevail over positive identification.

3. On the penalty and damages:
The crime of Robbery with Homicide is punishable by reclusion perpetua to death. In the absence of aggravating circumstances, the penalty of reclusion perpetua without eligibility for parole was correctly imposed pursuant to Republic Act No. 9346. However, the Court modified the damages in line with prevailing jurisprudence:
– Civil indemnity: ₱100,000.00
– Moral damages: ₱100,000.00
– Exemplary damages: ₱100,000.00
– Actual damages (supported by receipts): ₱50,000.00
– Interest at 6% per annum on all damages from finality of judgment until fully paid.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court finding accused-appellant Juan Dela Cruz GUILTY of Robbery with Homicide is AFFIRMED with MODIFICATION in the award of damages as specified above. Costs against accused-appellant.

SO ORDERED.