G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: J. PERFECTO

FACTS

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, in Quezon City, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed, resulting in his death.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family reunion at the time of the incident. The trial court found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua without eligibility for parole, 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 giving credence to the testimony of the lone eyewitness.

—

ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi can prevail over positive identification by an eyewitness.
3. Whether the penalty imposed is correct.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Court ruled that the prosecution successfully proved the guilt of the accused beyond reasonable doubt. The testimony of eyewitness Maria Reyes was clear, consistent, and credible. She positively identified Dela Cruz as the perpetrator, and her testimony was corroborated by physical evidence, including the recovery of the knife with the victim’s blood and the stolen items in Dela Cruz’s possession.

The defense’s claim of inconsistencies in Reyes’ testimony was minor and did not affect her credibility. In fact, minor inconsistencies may even strengthen credibility as they indicate that the testimony was not rehearsed.

2. On the defense of alibi versus positive identification.

The defense of alibi cannot prevail over the positive identification of the accused by a credible eyewitness. 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 prove physical impossibility, as the location of the family reunion was only two hours away from the crime scene.

Positive identification, when categorical and consistent, prevails over alibi and denial.

3. On the penalty imposed.

The crime of Robbery with Homicide is punishable by reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the penalty of reclusion perpetua without eligibility for parole is correct pursuant to Republic Act No. 9346 , which prohibits the imposition of the death penalty.

The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages, but modified the amounts in accordance with prevailing jurisprudence.

—

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 amounts of damages awarded. Accused-appellant is sentenced to suffer the penalty of reclusion perpetua without eligibility for parole and ordered to pay the heirs of Pedro Santos the following amounts:

– Civil indemnity: ₱75,000
– Moral damages: ₱75,000
– Exemplary damages: �₱75,000

All monetary awards shall earn interest at the rate of six percent (6%) per annum from the date of finality of this judgment until fully paid.

SO ORDERED.