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, in Quezon City, Dela Cruz, armed with a knife, entered the house 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 Santos, the victim’s wife, who testified that she saw Dela Cruz, whom she knew personally, stab her husband. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in Bulacan, about 50 kilometers away, 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 decision in toto. Hence, this appeal before the Supreme Court.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant based on the prosecution’s evidence and in rejecting his defense of alibi.

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

1. Credibility of Prosecution Witness
The Court upheld the findings of the RTC and CA regarding the credibility of eyewitness Maria Santos. Her positive identification of Dela Cruz as the perpetrator was clear, categorical, and consistent. The Court emphasized that positive identification prevails over alibi, especially when the witness has no ill motive to falsely testify.

2. Weakness of Alibi Defense
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 be at the crime scene. Dela Cruz failed to establish physical impossibility, as Bulacan is only about 50 kilometers from Quezon City and accessible by various means of transportation within a few hours.

3. Elements of Robbery with Homicide
The Court found all elements present:
a) Robbery was committed by taking personal property with intent to gain;
b) Homicide was committed on the occasion or by reason of the robbery;
c) The homicide was perpetrated by the robber or their accomplice.
The taking of cash and jewelry, coupled with the killing of Pedro Santos during the robbery, satisfied these elements.

4. Aggravating Circumstance
The crime was committed in the dwelling of the victim, which is an aggravating circumstance under Article 14 of the Revised Penal Code. However, since the penalty for Robbery with Homicide is already reclusion perpetua to death, and no other modifying circumstances were present, the RTC correctly imposed reclusion perpetua.

5. Damages
The Court modified the damages awarded, increasing civil indemnity, moral damages, and exemplary damages in line with prevailing jurisprudence, and awarded temperate damages in lieu of actual damages due to insufficient receipts.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is AFFIRMED with MODIFICATION in the award of damages. Accused-appellant is ordered to pay the heirs of Pedro Santos:

– Civil indemnity: ₱100,000.00
– Moral damages: ₱100,000.00
– Exemplary damages: ₱100,000.00
– Temperate damages: ₱50,000.00

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

SO ORDERED.