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, 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 exemplary damages to the heirs of the victim. The Court of Appeals (CA) affirmed the RTC decision in toto.

Hence, this appeal before the Supreme Court.

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ISSUES

1. Whether the eyewitness identification of the accused was reliable and sufficient to sustain a conviction beyond reasonable doubt.
2. Whether the defense of alibi should be given credence.
3. Whether the crime committed was Robbery with Homicide or separate crimes of Robbery and Homicide.
4. Whether the damages awarded were proper.

RULING

1. On the reliability of the eyewitness identification:
The Supreme Court found the eyewitness identification reliable. Maria Santos had a clear view of the accused under sufficient lighting, and she knew him prior to the incident as a former neighbor. There was no evidence of improper motive to falsely testify. The Court reiterated the doctrine that positive identification, where categorical and consistent, prevails over alibi and denial.

2. On the defense of alibi:
The defense of alibi was rightly rejected. 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 be at the crime scene. The distance of 50 kilometers between Bulacan and Quezon City did not make it physically impossible for the accused to have been at the crime scene, given the availability of transportation. Alibi is inherently weak and cannot prevail over positive identification.

3. On the proper crime:
The Court affirmed that the crime committed was Robbery with Homicide, a special complex crime under Article 294 of the Revised Penal Code. The prosecution proved that the homicide was committed by reason or on the occasion of the robbery. The taking of personal property and the killing were intertwined; the killing was not a separate or independent act. Hence, the trial court correctly appreciated the special complex crime.

4. On the damages awarded:
The Supreme Court modified the damages in line with prevailing jurisprudence. The award of civil indemnity, moral damages, and exemplary damages for Robbery with Homicide is mandatory. The Court increased the amounts to conform to current guidelines:
– Civil indemnity: ₱100,000
– Moral damages: ₱100,000
– Exemplary damages: ₱100,000
– Temperate damages (in lieu of actual damages for unreceipted expenses): ₱50,000
– Actual damages (if supported by receipts) were deleted for lack of evidence.
All damages shall earn legal interest at 6% per annum from the finality of the 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 Robbery with Homicide is AFFIRMED with MODIFICATION in the award of damages as follows:

Accused-appellant is ordered to pay the heirs of Pedro Santos:
1. ₱100,000 as civil indemnity;
2. ₱100,000 as moral damages;
3. ₱100,000 as exemplary damages;
4. ₱50,000 as temperate damages; and
5. Interest at 6% per annum on all monetary awards from finality of this judgment until fully paid.

Costs against accused-appellant.

SO ORDERED.