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 forcibly took cash and jewelry. During the robbery, Pedro Santos resisted, and a struggle ensued, resulting in the accused stabbing and killing Pedro Santos.

The accused interposed the defense of alibi, claiming he was in a different city attending a family reunion at the time of the incident. The trial court found the accused guilty beyond reasonable doubt, giving full credence to the positive identification by an eyewitness, Maria Santos (the victim’s wife), who testified that she saw the accused clearly during the crime. The trial court sentenced him to reclusion perpetua and ordered him to pay civil indemnity, moral damages, and exemplary damages.

The accused appealed, arguing that the trial court erred in: (1) giving credence to the eyewitness identification; (2) not considering his defense of alibi; and (3) convicting him despite alleged inconsistencies in the prosecution’s evidence.

—

ISSUES

1. Whether the eyewitness identification of the accused was reliable and sufficient to sustain a conviction.
2. Whether the defense of alibi should prevail over positive identification.
3. Whether there were inconsistencies in the prosecution’s evidence that cast reasonable doubt on the accused’s guilt.

RULING

1. On the reliability of the eyewitness identification:
The Court found the eyewitness identification reliable. Maria Santos had a clear view of the accused during the incident, as the crime occurred in her well-lit living room, and she was face-to-face with the accused for several minutes. She had no motive to falsely testify against the accused. The Court has consistently held that positive identification, when categorical and consistent, prevails over alibi and denial.

2. On the defense of alibi:
The defense of alibi must fail. 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. The accused failed to establish physical impossibility, as the distance between the crime scene and his alleged location was not insurmountable within the time frame. Alibi is inherently weak and cannot prevail over positive identification.

3. On alleged inconsistencies:
The alleged inconsistencies in the prosecution’s evidence were minor and did not affect the core of the prosecution’s narrative. Inconsistencies on trivial matters may even enhance the credibility of a witness, as they indicate that the testimony was not rehearsed. The core testimony of Maria Santos—that she saw the accused rob and kill her husband—remained unwavering and credible.

—

DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court finding accused-appellant Juan dela Cruz GUILTY beyond reasonable doubt of Robbery with Homicide is AFFIRMED with MODIFICATION. Accused-appellant is sentenced to reclusion perpetua and ordered to pay the heirs of Pedro Santos the following amounts:

– Civil Indemnity: ₱100,000.00
– Moral Damages: ₱100,000.00
– Exemplary Damages: ₱100,000.00
– Temperate Damages: ₱50,000.00

All monetary awards shall earn interest at the rate of six percent (6%) per annum from the finality of this Decision until fully paid.

SO ORDERED.