G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: PER CURIAM

FACTS

Accused-appellant Juan Dela Cruz was charged with the crime of Robbery with Homicide under Article 294(1) of the Revised Penal Code. The prosecution alleged that on January 15, 2010, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. In the course of the robbery, Dela Cruz stabbed Santos, causing his death, and took cash and jewelry.

During trial, the prosecution presented eyewitness Maria Santos, the victim’s wife, who positively identified Dela Cruz as the perpetrator. She testified that she saw Dela Cruz inside their house, struggling with her husband, before stabbing him and fleeing with a bag containing valuables. The defense, on the other hand, interposed the defense of alibi, claiming Dela Cruz was in a different city at the time of the incident.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua, without eligibility for parole, 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.

—

ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi can prevail over positive identification.
3. Whether the penalty imposed is correct.

RULING

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

The Court upheld the findings of the lower courts. The positive identification of the accused by eyewitness Maria Santos was clear, categorical, and consistent. She had a clear view of the incident, and there was no ill motive attributed to her that would impugn her testimony. The defense failed to cast any reasonable doubt on her credibility.

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

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. Dela Cruz’s alibi failed this test. The distance between the crime scene and his alleged location was not insurmountable, making it possible for him to have committed the crime. Positive identification, when credible, always prevails over alibi.

3. The penalty imposed is correct.

Under Article 294(1) of the Revised Penal Code, Robbery with Homicide is punishable by reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the penalty imposed by the RTC and affirmed by the CA—reclusion perpetua without eligibility for parole—is in accordance with law and prevailing jurisprudence. The award of damages is likewise affirmed, with modifications in accordance with recent case law to include temperate damages.

—

DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Court of Appeals affirming the Regional Trial Court’s conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is AFFIRMED with MODIFICATION. Accused-appellant is sentenced to suffer the penalty of reclusion perpetua without eligibility for parole and ordered to pay the heirs of Pedro Santos the following amounts:

– Civil indemnity: ₱100,000.00
– Moral damages: ₱100,000.00
– Exemplary damages: ₱100,000.00
– Temperate damages: ₱50,000.00

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

SO ORDERED.