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

The prosecution presented an eyewitness, Maria Lopez, a neighbor who testified that she saw Dela Cruz fleeing the scene with a bloodied knife. The defense, however, presented an alibi, claiming that Dela Cruz was in a different city attending a family reunion at the time of the incident. The trial court convicted Dela Cruz, sentencing him to reclusion perpetua and ordering him to pay civil indemnity, moral damages, and exemplary damages to the victim’s heirs.

Dela Cruz appealed, arguing that the prosecution failed to prove his guilt beyond reasonable doubt and that the eyewitness identification was unreliable.

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ISSUES

1. Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
2. Whether the eyewitness identification was credible and sufficient to sustain a conviction.
3. Whether the alibi of the accused should be given credence.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.
The Court found that the prosecution evidence, particularly the positive identification by eyewitness Maria Lopez, was credible and consistent. Lopez testified in a clear and straightforward manner, and her testimony was corroborated by physical evidence, including the recovery of the bloodied knife and stolen items in Dela Cruz’s possession. The defense failed to show any ill motive on the part of Lopez to falsely testify against the accused.

2. The eyewitness identification was credible and sufficient to sustain a conviction.
The Court held that Lopez had a sufficient opportunity to identify Dela Cruz, as the crime occurred in a well-lit area, and she had known Dela Cruz prior to the incident. Her testimony remained unwavering during cross-examination. Positive identification prevails over alibi and denial, especially when the witness has no reason to fabricate charges.

3. The alibi of the accused cannot prevail over positive identification.
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 scene of the crime. Dela Cruz failed to establish the physical impossibility of his presence at the crime scene, as the distance between the two locations was not insurmountable. Alibi is inherently weak and easily fabricated, and it cannot overcome the positive testimony of a credible witness.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court convicting accused-appellant Juan Dela Cruz of Robbery with Homicide and sentencing him to reclusion perpetua is AFFIRMED with MODIFICATION. Accused-appellant is ordered to pay the heirs of Pedro Santos the following amounts:

– Civil Indemnity: ₱75,000.00
– Moral Damages: ₱75,000.00
– Exemplary Damages: ₱75,000.00
– Temperate Damages: ₱50,000.00

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

SO ORDERED.