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 found the eyewitness identification reliable. Maria Santos had sufficient opportunity to see the accused during the commission of the crime. The room was illuminated, and she had known the accused prior to the incident as a former neighbor. There was no evidence of improper motive to falsely testify against him. Positive identification, when categorical and consistent, prevails over alibi and denial.

2. On the defense of alibi:
The defense of alibi was rightly rejected. 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. The distance of 50 kilometers between Bulacan and Quezon City did not render it impossible for the accused to have traveled to the crime scene. Alibi is inherently weak and cannot prevail over positive identification.

3. On the proper crime:
The Court held that the crime committed was Robbery with Homicide, a special complex crime under Article 294 of the Revised Penal Code. The prosecution proved that the homicide was committed by reason or on the occasion of the robbery. The taking of personal property with intent to gain and the killing of the victim were shown to be intimately connected. The trial court correctly appreciated the aggravating circumstance of dwelling, since the crime was committed in the victim’s house, which increased the penalty.

4. On the damages awarded:
The Court modified the damages awarded in line with prevailing jurisprudence. The accused was ordered to pay:
– Civil indemnity: ₱75,000
– Moral damages: ₱75,000
– Exemplary damages: ₱75,000
– Temperate damages: ₱50,000 (in lieu of actual damages, since no receipts were presented but the fact of loss was proven)
– 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 the crime of Robbery with Homicide is AFFIRMED with MODIFICATION in the award of damages as stated above. Costs against accused-appellant.

SO ORDERED.