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 held that the eyewitness identification was unreliable. The Court noted that while Maria Santos claimed to have recognized the accused, the circumstances cast doubt on her ability to do so. She testified that the incident happened quickly, the accused wore a cap that partially covered his face, and she was in a state of shock and fear. Moreover, there was no prior police identification procedure (e.g., lineup) conducted. The Court emphasized that for eyewitness identification to be credible, it must be positive, categorical, consistent, and not influenced by improper motive. In this case, the identification failed to meet these standards.

2. On the defense of alibi:
The Court ruled that the defense of alibi cannot prevail over positive identification. However, since the positive identification was found to be weak and unreliable, the alibi gains significance. The defense presented corroborative evidence, including testimonies of barangay officials and photographs, placing the accused in Bulacan during the time of the crime. The distance of 50 kilometers was not too far to preclude the possibility of the accused being at the crime scene, but given the weak prosecution evidence, the alibi created reasonable doubt.

3. On the proper crime:
The Court found that the prosecution failed to prove the element of “taking with intent to gain” (animus lucrandi) as a primary purpose. The evidence showed that the killing may have preceded the taking, and the taking was merely incidental. Thus, the special complex crime of Robbery with Homicide was not proven. Instead, the accused should be held liable for the separate crimes of Homicide and Theft, if proven. However, since the identification of the accused as the perpetrator was doubtful, the Court acquitted him.

4. On the damages awarded:
In view of the acquittal, the award of damages is deleted.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is GRANTED. 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 REVERSED and SET ASIDE. Accused-appellant Juan dela Cruz is ACQUITTED on the ground of reasonable doubt. He is ordered IMMEDIATELY RELEASED from detention unless he is being held for another lawful cause. The award of damages is DELETED.

SO ORDERED.