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, supported by the testimonies of his relatives.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt, 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 prevail over the positive identification by the eyewitness.
3. Whether the award of damages is proper.

RULING

1. On the proof of guilt beyond reasonable doubt.

The Supreme Court AFFIRMED the conviction. The Court held that the prosecution successfully established the elements of Robbery with Homicide:

– Taking of personal property The eyewitness testified that she saw the accused take cash and jewelry.
– With intent to gain The unlawful taking clearly demonstrated animus lucrandi.
– With violence or intimidation against persons The accused was armed with a knife.
– Homicide was committed The victim died as a result of the stab wounds inflicted during the robbery.

The Court emphasized that the positive identification by the eyewitness, who had no ill motive to falsely testify, prevailed over the defense of alibi. Her testimony was clear, consistent, and credible.

2. On the defense of alibi versus positive identification.

The Court REJECTED the defense of alibi. Jurisprudence consistently holds that alibi is a weak defense and cannot prevail over the positive identification of the accused by a credible witness. 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. Here, the accused failed to prove the physical impossibility, as Bulacan is not so far from Quezon City as to preclude his presence at the crime scene.

3. On the award of damages.

The Court MODIFIED the award of damages in line with prevailing jurisprudence. The accused is 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 established)
– 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 is AFFIRMED with MODIFICATION in the award of damages as stated above. Costs against accused-appellant.

SO ORDERED.