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, 2015, in Quezon City, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, and took cash and jewelry valued at ₱50,000. During the robbery, Santos resisted, and Dela Cruz stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw Dela Cruz, whom she recognized as a former neighbor, inside their house and witnessed the stabbing. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in Bulacan, 50 kilometers away, attending a fiesta at the time of the incident. The defense presented two witnesses to corroborate his alibi.

The Regional Trial Court (RTC) found Dela Cruz 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 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. The prosecution proved the guilt of the accused beyond reasonable doubt.

The Supreme Court upheld the findings of the lower courts. The positive identification of the accused by eyewitness Maria Santos, who had no ill motive to testify falsely, prevails over the defense of alibi. The Court emphasized that alibi is inherently weak and easily fabricated, and it cannot prevail over the positive testimony of a credible witness who categorically identified the accused as the perpetrator.

Moreover, 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 scene of the crime. Dela Cruz failed to prove the physical impossibility, as Bulacan is only 50 kilometers from Quezon City and accessible by various modes of transportation within a few hours.

2. The defense of alibi cannot prevail over positive identification.

The Court reiterated the well-settled doctrine that positive identification, where categorical and consistent and without any showing of ill motive on the part of the eyewitness, is accorded greater weight than alibi. Maria Santos’ testimony was clear, straightforward, and consistent on material points. She had known Dela Cruz prior to the incident, having been neighbors for several years, making her identification reliable.

3. The award of damages is proper but must be modified in accordance with prevailing jurisprudence.

The Supreme Court sustained the award of civil indemnity, moral damages, and exemplary damages. However, following recent jurisprudence, the Court modified the amounts to conform to current standards:

– Civil indemnity: ₱75,000
– Moral damages: ₱75,000
– Exemplary damages: ₱75,000

Additionally, the Court imposed interest at the rate of 6% per annum on all damages awarded from the date of finality of the 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 follows:

1. Accused-appellant is ordered to pay the heirs of Pedro Santos:
– Civil indemnity: ₱75,000
– Moral damages: ₱75,000
– Exemplary damages: ₱75,000
2. All monetary awards shall earn interest at 6% per annum from the finality of this judgment until fully paid.

Costs against accused-appellant.

SO ORDERED.