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 Santos, the victim’s wife, who testified that she saw the accused inside their house and recognized him because the room was well-lit. She claimed she knew the accused as a former neighbor. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in Bulacan attending a fiesta at the time of the incident, which was about 50 kilometers away.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of the accused based on the eyewitness identification, despite the defense of alibi and alleged inconsistencies in the prosecution’s evidence.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of the accused.

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RATIONALE

1. Credibility of Eyewitness Testimony
The Court held that the eyewitness identification by Maria Santos was credible and reliable. She had a clear view of the accused, whom she recognized as a former neighbor, and her testimony remained consistent on material points throughout the trial. Minor inconsistencies regarding peripheral details do not affect the credibility of a witness, especially when the core testimony of witnessing the crime is steadfast.

2. Defense of Alibi
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 elsewhere when the crime was committed but also that it was physically impossible for him to have been at the crime scene. The distance of 50 kilometers between Bulacan and Quezon City is not an insurmountable distance, especially with available transportation. Hence, the defense of alibi must fail.

3. Elements of Robbery with Homicide
All elements of Robbery with Homicide under Article 294 of the Revised Penal Code were proven beyond reasonable doubt:
a) There was a taking of personal property with intent to gain;
b) The taking was with violence or intimidation against persons;
c) The robbery resulted in homicide.
The prosecution established that the accused took cash and jewelry and, in the process, killed the victim. The homicide was committed by reason or on occasion of the robbery.

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 penalty of reclusion perpetua was correctly imposed by the lower courts.

5. Damages
The Court affirmed the award of civil indemnity, moral damages, and exemplary damages to the heirs of the victim, in line with prevailing jurisprudence.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan dela Cruz for the crime of Robbery with Homicide and sentencing him to suffer the penalty of reclusion perpetua is AFFIRMED with modification increasing the awards for damages in accordance with current jurisprudence.

SO ORDERED.