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, 2018, Dela Cruz, armed with a knife, entered the residence of the victim, Pedro Santos, with intent to rob. During the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos. The prosecution presented eyewitness testimony from Maria Santos, the victim’s wife, who identified Dela Cruz as the perpetrator. 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’s 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 defense of 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

The Court held:

1. Credibility of Prosecution Witness. The testimony of eyewitness Maria Santos was clear, consistent, and credible. She positively identified Dela Cruz as the person who entered their home, demanded money, and stabbed her husband. The Court gives great weight to the trial court’s assessment of witness credibility, as it had the direct opportunity to observe the witness’s demeanor. No ill motive was shown for Maria Santos to falsely testify against the accused.

2. Elements of Robbery with Homicide Proven. All elements of the special complex crime of Robbery with Homicide were established:
The taking of personal property with intent to gain (money was demanded and taken from the victim);
The taking was with violence or intimidation against a person (the armed entry and struggle);
On the occasion of the robbery, homicide was committed (the killing of Pedro Santos).
The homicide is regarded as a single component of the robbery, and it is not necessary to prove that the killing was intentional for the crime to be Robbery with Homicide; it is sufficient that the death occurred by reason or on the occasion of the robbery.

5. Penalty. The penalty for Robbery with Homicide under Article 294(1) is reclusion perpetua* to death. In the absence of any aggravating or mitigating circumstance, the lesser penalty of reclusion perpetua was correctly imposed by the lower courts. The Court also affirmed the awards of civil indemnity, moral damages, and exemplary damages to the heirs of the victim, consistent with prevailing jurisprudence.

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DISPOSITIVE PORTION

WHEREFORE, the Decision of the Court of Appeals is AFFIRMED. Accused-appellant JUAN DELA CRUZ is found GUILTY beyond reasonable doubt of the crime of Robbery with Homicide and is sentenced to suffer the penalty of RECLUSION PERPETUA. He is ordered to pay the heirs of the victim Pedro Santos the amounts of Php 100,000.00 as civil indemnity, Php 100,000.00 as moral damages, and Php 100,000.00 as exemplary damages, all with legal interest at the rate of six percent (6%) per annum from the finality of this judgment until fully paid.

SO ORDERED.