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, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the robbery, Dela Cruz stabbed Santos, causing his death, and took cash and jewelry valued at ₱50,000.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw Dela Cruz, whom she recognized as a former neighbor, stab her husband and ransack their bedroom. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in Bulacan, 50 kilometers away, attending a fiesta at the time of the incident. Dela Cruz presented three witnesses to corroborate his alibi.

The Regional Trial Court (RTC) convicted Dela Cruz, giving full credence to the eyewitness identification and rejecting the alibi. The RTC sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and actual damages. The Court of Appeals (CA) affirmed the RTC decision in toto.

ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should prevail over the positive identification by the eyewitness.
3. Whether the award of damages is proper.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.

The Supreme Court affirmed the conviction. The Court held that the positive identification by the eyewitness, Maria Santos, who had no ill motive to falsely testify, was clear, consistent, and credible. She had a sufficient opportunity to see the accused during the commission of the crime, as the room was well-lit, and she recognized him as a former neighbor. Positive identification, when categorical and consistent, prevails over alibi and denial.

2. The defense of alibi cannot prevail over positive identification.

The defense of alibi is inherently weak and must be supported by clear and convincing evidence that the accused was so far away that it was physically impossible for him to be at the scene of the crime. In this case, Bulacan is only 50 kilometers from Quezon City, and travel by vehicle would take roughly 1.5 to 2 hours. Thus, it was not physically impossible for Dela Cruz to have been at the crime scene. Alibi cannot stand against the positive testimony of a credible eyewitness.

3. The award of damages is modified in line with prevailing jurisprudence.

The Supreme Court sustained the awards for civil indemnity and moral damages but modified the actual damages. Since the prosecution failed to present receipts for the stolen jewelry and cash, the Court deleted the award of actual damages. Instead, the Court awarded temperate damages in the amount of ₱25,000, in lieu of actual damages, as the fact of loss was established by testimony. Additionally, exemplary damages of ₱30,000 were awarded due to the presence of the aggravating circumstance of dwelling.

DISPOSITIVE PORTION

WHEREFORE, the Decision of the Court of Appeals is AFFIRMED with MODIFICATION. Accused-appellant Juan Dela Cruz is found GUILTY beyond reasonable doubt of Robbery with Homicide and is sentenced to reclusion perpetua. He is ordered to pay the heirs of Pedro Santos the following amounts:

– Civil indemnity: ₱75,000
– Moral damages: ₱75,000
– Temperate damages: ₱25,000
– Exemplary damages: ₱30,000

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

SO ORDERED.