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(1) of the Revised Penal Code. The prosecution alleged that on January 15, 2010, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the robbery, Santos was stabbed multiple times, resulting in his death. Cash and jewelry were taken.

The prosecution presented an eyewitness, Maria Santos (the victim’s wife), who testified that she saw Dela Cruz, whom she knew personally, stab her husband. The defense, on the other hand, interposed the defense of alibi, claiming that 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. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant for Robbery with Homicide despite the alleged weakness of the prosecution’s evidence and the strength of his alibi.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide.

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RATIONALE:

1. Credibility of Prosecution Witness.
The Court upheld the findings of the RTC and CA regarding the credibility of Maria Santos. Her positive identification of Dela Cruz as the perpetrator was clear, categorical, and consistent. The defense failed to show any ill motive on her part to falsely testify against the accused. Positive identification prevails over alibi, especially when the witness knew the accused prior to the incident.

2. Alibi as a Defense.
For alibi to prosper, the accused must prove not only that he was elsewhere 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 establish physical impossibility. The distance between the crime scene and his claimed location was not so great as to preclude his presence at the scene. Alibi is inherently weak and easily fabricated.

3. Elements of Robbery with Homicide.
The Court found all elements present:
a) Taking of personal property with intent to gain proven by the missing cash and jewelry;
b) Use of violence or intimidation against a person proven by the stabbing;
c) Homicide was committed as a consequence or on the occasion of the robbery proven by the fatal wounds inflicted during the robbery.
The prosecution established the unity of criminal purposethe homicide was perpetrated to facilitate the robbery or escape.

4. Treachery and Evident Premeditation.
The Court agreed with the lower courts that treachery attended the killing. The attack was sudden and unexpected, giving the victim no opportunity to defend himself. However, evident premeditation was not proven, as there was no evidence of planning or preparation prior to the robbery.

5. Penalty.
Under Article 294(1) of the Revised Penal Code, when homicide is committed by reason or on the occasion of robbery, the penalty is reclusion perpetua to death. In the absence of aggravating circumstances, the imposable penalty is reclusion perpetua. The Court affirmed the penalty imposed by the RTC and CA.

6. Damages.
The Court modified the awards of damages in line with prevailing jurisprudence:
– Civil Indemnity: ₱100,000.00
– Moral Damages: ₱100,000.00
– Exemplary Damages: ₱100,000.00 (due to the presence of treachery)
– Actual Damages: As proven by receipts, or temperate damages if not fully 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 DENIED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is AFFIRMED with MODIFICATION as to the awards of damages. Accused-appellant is sentenced to suffer the penalty of reclusion perpetua and ordered to pay the heirs of Pedro Santos the amounts of ₱100,000.00 as civil indemnity, ₱100,000.00 as moral damages, ₱100,000.00 as exemplary damages, and ₱50,000.00 as temperate damages, with interest at 6% per annum from finality of this judgment until fully paid.

SO ORDERED.