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 also testified that she heard the accused demand money from her husband before stabbing him. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering at the time of the incident. The trial court convicted the accused, giving full credence to the eyewitness testimony and rejecting the alibi. The accused appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt.

ISSUE

Whether the trial court erred in convicting the accused of Robbery with Homicide based on the eyewitness identification, despite the defense of alibi and alleged inconsistencies in the prosecution’s evidence.

RULING

The Supreme Court AFFIRMED the conviction but MODIFIED the penalty and damages.

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RATIONALE

1. Credibility of Eyewitness Testimony
The Court upheld the trial court’s assessment of the eyewitness’s credibility. The witness, Maria Santos, had a clear and unobstructed view of the accused, whom she knew prior to the incident. Her positive identification prevailed over the defense of alibi, which was not corroborated by strong evidence of the physical impossibility of the accused being at the crime scene. The Court reiterated the doctrine that alibi is inherently weak and must be supported by credible corroboration.

2. Elements of Robbery with Homicide
The Court found all elements present:
a) The taking of personal property with intent to gain;
b) The taking was accomplished with violence or intimidation against a person;
c) The robbery resulted in homicide.
The prosecution proved that the homicide was committed by reason or on occasion of the robbery, as the killing occurred during the commission of the robbery.

3. Alleged Inconsistencies
The minor inconsistencies in the witness’s testimony regarding peripheral details (e.g., the exact time or sequence of shouts) did not affect her core testimony about the accused’s identity and actions. Such inconsistencies may even enhance credibility by showing that the testimony was not rehearsed.

4. Penalty and Damages
The Court modified the penalty. Since Robbery with Homicide is punishable by reclusion perpetua to death, and no aggravating or mitigating circumstances were proven, the penalty of reclusion perpetua was properly imposed. However, the Court increased the awards for damages in line with recent jurisprudence:
– Civil indemnity: ₱100,000
– Moral damages: ₱100,000
– Exemplary damages: ₱100,000
– Actual damages (supported by receipts): ₱50,000
– Interest at 6% per annum on all damages from finality until full payment.

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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. He is sentenced to reclusion perpetua and ordered to pay the heirs of Pedro Santos the following amounts:
– ₱100,000 as civil indemnity;
– ₱100,000 as moral damages;
– ₱100,000 as exemplary damages;
– ₱50,000 as actual damages; and
– Interest at 6% per annum on all damages awarded from finality until fully paid.

Costs against accused-appellant.

SO ORDERED.