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, 2015, 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 Reyes, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in Bulacan, 50 kilometers away, attending a family reunion at the time of the incident. Several relatives corroborated his alibi.

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.

Dela Cruz appealed to the Supreme Court via a petition for review on certiorari, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that his alibi was wrongly disregarded.

—

ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the defense of alibi should be given credence in light of the positive identification by an eyewitness.
3. Whether the penalty and damages imposed were proper.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Supreme Court AFFIRMED the conviction. The Court held that the positive identification of the accused by eyewitness Maria Reyes was clear, categorical, and consistent. She had no motive to falsely testify against Dela Cruz. Her testimony, coupled with the circumstantial evidence (the accused fleeing with a bloodied knife), established moral certainty of his guilt.

The Court reiterated the doctrine that positive identification prevails over alibi and denial. 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 be at the scene of the crime. Here, Bulacan is only 50 kilometers from Quezon City, and travel by vehicle was possible within the timeframe. Thus, physical impossibility was not established.

2. On the defense of alibi.

The defense of alibi was correctly rejected. The Court emphasized that alibi is inherently weak and easily fabricated. It cannot prevail over the positive testimony of a credible witness who identified the accused as the perpetrator. The corroboration by relatives, who are naturally partial to the accused, adds little weight.

3. On the penalty and damages.

The penalty for Robbery with Homicide under Article 294 of the Revised Penal Code is reclusion perpetua to death. With no aggravating or mitigating circumstances, the RTC correctly imposed reclusion perpetua, pursuant to prevailing jurisprudence.

The Court MODIFIED the damages awarded, following recent guidelines in criminal cases:
– Civil indemnity: ₱100,000
– Moral damages: ₱100,000
– Exemplary damages: ₱100,000
– Temperate damages: ₱50,000 (in lieu of actual damages, since no receipts were presented but loss was proven)
– Interest: 6% per annum on all damages from finality of judgment until fully paid.

—

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 stated above. Costs against accused-appellant.

SO ORDERED.