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, with intent to rob. During the commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented an eyewitness, Maria Reyes, a neighbor who claimed to have seen Dela Cruz fleeing the scene.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. Several relatives testified to corroborate his presence elsewhere.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt, giving full credence to the eyewitness testimony and rejecting the alibi. The RTC sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal.

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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 over the positive identification by an eyewitness.
3. Whether the award of damages is proper and in accordance with prevailing jurisprudence.

RULING

1. On the proof of guilt beyond reasonable doubt YES.

The Court affirmed the findings of the lower courts. The eyewitness, Maria Reyes, gave a clear, consistent, and credible account of the incident. She positively identified Dela Cruz as the perpetrator, noting distinctive features and clothing. Her testimony was straightforward and remained unshaken during cross-examination. The defense failed to impute any ill motive on her part to falsely testify.

The elements of Robbery with Homicide were all established: (a) the taking of personal property with intent to gain; (b) with violence or intimidation against a person; (c) the property taken belongs to another; (d) the taking is without the consent of the owner; and (e) on the occasion of the robbery, homicide was committed. The prosecution evidence sufficiently proved these elements.

2. On the defense of alibi NO.

The defense of alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness. For 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. The distance between the crime scene and the location of the family gathering was not so great as to preclude his presence at the locus criminis. Moreover, alibi becomes even less credible when, as here, there is no corroboration from disinterested witnesses.

3. On the award of damages MODIFIED.

The Court found the awards in line with current jurisprudence but made adjustments to conform to the guidelines in People v. Jugueta ( G.R. No. 202124 , April 5, 2016) and subsequent cases.

The Court MODIFIED the damages as follows:
– Civil Indemnity: ₱75,000.00
– Moral Damages: ₱75,000.00
– Exemplary Damages: ₱75,000.00
– Temperate Damages: ₱50,000.00 (in lieu of actual damages, which were not fully substantiated)
– Interest: All monetary awards shall earn legal interest at the rate of 6% per annum from the date of finality of this judgment until fully paid.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz for the crime of Robbery with Homicide is AFFIRMED with MODIFICATION in the award of damages as specified above. Costs against accused-appellant.

SO ORDERED.