G.R. No. 123456
PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. JUAN DELA CRUZ, Accused-Appellant.

Ponente: PER CURIAM

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, Maria Santos, with intent to rob. In the course of the robbery, he stabbed and killed Santos. The prosecution presented eyewitness testimony from a neighbor, security camera footage showing Dela Cruz entering and leaving the vicinity, and forensic evidence linking Dela Cruz to the crime scene.

The defense interposed the defense of alibi, claiming Dela Cruz was in a different city at the time of the crime. The trial court found the prosecution’s evidence sufficient to establish guilt beyond reasonable doubt, convicted Dela Cruz, and sentenced him to reclusion perpetua without eligibility for parole. The court also ordered him to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim.

Dela Cruz appealed, arguing that the prosecution failed to prove his identity as the perpetrator beyond reasonable doubt and that the trial court erred in giving credence to the eyewitness’s testimony, which he claimed was inconsistent and unreliable.

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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 be given credence.
3. Whether the damages awarded are in accordance with law and jurisprudence.

RULING

1. On the proof of guilt beyond reasonable doubt.
The Court affirmed the conviction. The prosecution evidence, taken together, established Dela Cruz’s guilt beyond reasonable doubt. The eyewitness positively identified Dela Cruz, and this testimony was consistent and credible. The security footage, while not showing the actual crime, placed Dela Cruz near the scene at the time of the crime. Forensic evidence, including fingerprints and DNA, further corroborated his presence inside the victim’s residence. The defense’s attack on the eyewitness’s credibility was unavailing; minor inconsistencies did not affect the witness’s core testimony. Positive identification prevails over alibi and denial.

2. On the defense of alibi.
The defense of alibi is inherently weak and 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 crime scene. Dela Cruz failed to establish physical impossibility. The distance between the crime scene and his alleged location was not so great as to preclude his presence at the crime scene.

3. On the damages awarded.
The Court modified the damages in line with prevailing jurisprudence. For the crime of Robbery with Homicide, the following are awarded:
– Civil indemnity: ₱100,000.00
– Moral damages: ₱100,000.00
– Exemplary damages: ₱100,000.00
– Temperate damages: ₱50,000.00 (in lieu of actual damages for loss of earning capacity, since no receipt was presented but the fact of loss was established)
– Interest: 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 Regional Trial Court convicting accused-appellant Juan Dela Cruz of Robbery with Homicide is AFFIRMED with MODIFICATION in the award of damages as stated above. Costs against accused-appellant.

SO ORDERED.