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 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 affirmed the RTC decision in toto.

Hence, this appeal before the Supreme Court.

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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.

RULING

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

The Supreme Court held that the prosecution successfully established all elements of Robbery with Homicide: (a) the taking of personal property with intent to gain, (b) with violence or intimidation against a person, (c) and on the occasion thereof, homicide was committed.

The positive identification by eyewitness Maria Reyes was clear, consistent, and credible. She had no ill motive to falsely testify against the accused. Her testimony was corroborated by physical evidence, including the stolen items recovered from Dela Cruz’s possession and the autopsy report consistent with her account.

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 prove physical impossibility, as the city where he claimed to be was only a few hours away by vehicle. The testimony of relatives is naturally suspect due to bias.

3. On the award of damages MODIFIED.

The Court affirmed the awards for civil indemnity and moral damages in the amount of ₱75,000.00 each. However, it increased the award for exemplary damages from ₱30,000.00 to ₱75,000.00, in line with prevailing jurisprudence, because the crime was committed with a deadly weapon and attended by treachery. Actual damages were deleted for lack of sufficient receipts, but in lieu thereof, temperate damages of ₱50,000.00 were awarded. All monetary awards shall earn interest at 6% per annum from the finality of 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 follows:

1. Accused-appellant is ordered to pay the heirs of Pedro Santos:
Civil Indemnity ₱75,000.00;
Moral Damages ₱75,000.00;
Exemplary Damages ₱75,000.00;
Temperate Damages ₱50,000.00.
2. All monetary awards shall earn legal interest at the rate of six percent (6%) per annum from the finality of this judgment until fully paid.

SO ORDERED.