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, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented an eyewitness, Maria Reyes, a neighbor who claimed to have seen Dela Cruz fleeing the scene.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. Several relatives testified to corroborate his presence elsewhere.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt, giving full credence to the eyewitness testimony 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 prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should be given credence over the positive identification by an eyewitness.
3. Whether the award of damages is proper.

RULING

1. On the proof of guilt beyond reasonable doubt YES.

The Supreme Court held that the prosecution successfully established all elements of Robbery with Homicide:
– Taking of personal property belonging to another The victim’s wallet and cash were missing.
– With intent to gain (animus lucrandi) Inferred from the unlawful taking.
– With violence or intimidation against persons The killing of Pedro Santos.
– Homicide was committed by reason or on occasion of the robbery The killing occurred during the struggle to consummate the robbery.

The Court emphasized that the positive identification by eyewitness Maria Reyes, who had no ill motive to testify falsely, prevailed over the defense of alibi. Her testimony was clear, consistent, and credible on material points.

2. On the defense of alibi vs. positive identification NO, alibi cannot prevail.

The Court reiterated the 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 somewhere else 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 prove physical impossibility, as the city where he claimed to be was only a few hours away by vehicle.

3. On the award of damages MODIFIED.

The Court affirmed the awards but adjusted them in accordance with prevailing jurisprudence:
– Civil indemnity: ₱75,000.00
– Moral damages: ₱75,000.00
– Exemplary damages: ₱75,000.00 (in view of the aggravating circumstance of dwelling)
– Temperate damages: ₱50,000.00 (in lieu of actual damages for unreceipted funeral expenses)
– Interest at 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 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 specified above. Costs against accused-appellant.

SO ORDERED.