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, 2015, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the robbery, Santos resisted, and Dela Cruz stabbed him multiple times, causing his death. Dela Cruz then took cash and jewelry worth ₱50,000.

During trial, the prosecution presented an eyewitness, Maria Lopez, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, presented an alibi, claiming that Dela Cruz was in a different city attending a family reunion at the time of the crime. The trial court convicted Dela Cruz, finding the eyewitness testimony credible and the alibi weak. The court sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim.

Dela Cruz appealed, arguing that the trial court erred in giving credence to the eyewitness testimony, which he claimed was inconsistent and unreliable. He also contended that his alibi was supported by credible witnesses and that the prosecution failed to prove his guilt beyond reasonable doubt.

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ISSUES

1. Whether the eyewitness testimony of Maria Lopez is credible and sufficient to establish the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should prevail over the positive identification of the accused.
3. Whether the trial court correctly imposed the penalty of reclusion perpetua and the awarded damages.

RULING

1. On the credibility of the eyewitness testimony.
The Court upheld the trial court’s assessment of Maria Lopez’s credibility. The alleged inconsistencies in her testimony pertained to minor details that did not affect the core of her account—that she saw Dela Cruz fleeing the crime scene with a bloodied knife. The Court emphasized that minor inconsistencies may even strengthen credibility, as they indicate that the testimony was not rehearsed. Moreover, Lopez had no motive to falsely testify against Dela Cruz. Her positive identification, given in a clear and straightforward manner, prevailed over the general denial of the accused.

2. On the defense of alibi.
The Court reiterated the well-established doctrine that 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. Dela Cruz failed to establish physical impossibility, as the distance between the crime scene and the location of the family reunion was not insurmountable within the timeframe of the crime. Thus, the defense of alibi must fail.

3. On the penalty and damages.
The crime of Robbery with Homicide under Article 294(1) of the Revised Penal Code is punishable by reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the trial court correctly imposed reclusion perpetua, pursuant to prevailing jurisprudence. However, the Court modified the awards for damages in line with recent guidelines:

– Civil indemnity: ₱100,000
– Moral damages: ₱100,000
– Exemplary damages: ₱100,000
– Actual damages: ₱50,000 (as proven by receipts)
– Interest: 6% per annum on all damages from finality of judgment until fully paid.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court convicting accused-appellant Juan Dela Cruz of Robbery with Homicide is AFFIRMED with MODIFICATION in the awards for damages as specified above. Costs against accused-appellant.

SO ORDERED.