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, 2010, Dela Cruz, armed with a knife, entered the house of the victim, Pedro Santos, with intent to rob. During the robbery, Dela Cruz stabbed Santos, causing his death. The prosecution presented an eyewitness, Maria Reyes, who testified that she saw Dela Cruz fleeing the scene of the crime holding a bloodied knife.

The defense interposed the defense of alibi, claiming that Dela Cruz was in a different city attending a family gathering at the time of the incident. The defense presented several family members to corroborate his alibi.

The Regional Trial Court (RTC) found Dela Cruz guilty beyond reasonable doubt and sentenced him to reclusion perpetua. The RTC gave more credence to the positive identification by the eyewitness over the defense of alibi. The Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant based on the eyewitness identification, despite the defense of alibi and alleged inconsistencies in the prosecution’s evidence.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of accused-appellant Juan Dela Cruz.

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RATIONALE

1. Positive Identification Over Alibi
The Court reiterated the well-established doctrine that positive identification by a credible witness prevails over the defense of alibi. Alibi is inherently weak and must be supported by clear and convincing evidence that it was physically impossible for the accused to be at the crime scene. In this case, Dela Cruz failed to prove that it was impossible for him to be at the victim’s house at the time of the crime. The distance between the crime scene and the place where he claimed to be was not insurmountable, and his witnesses were all relatives whose testimonies were deemed biased.

2. Credibility of Eyewitness Testimony
The Court found the testimony of eyewitness Maria Reyes to be credible, consistent, and given in a straightforward manner. Minor inconsistencies in her testimony regarding peripheral details (e.g., the exact time or weather conditions) do not affect her credibility but instead indicate that her testimony was not rehearsed. Her positive identification of Dela Cruz as the perpetrator was categorical and unwavering.

3. Elements of Robbery with Homicide
All elements of Robbery with Homicide were proven beyond reasonable doubt:
a) Taking of personal property Cash and jewelry were stolen from the victim’s house.
b) With intent to gain The unlawful taking was established.
c) With violence or intimidation The robbery was accomplished by means of violence.
d) Homicide The killing of Pedro Santos occurred by reason or on occasion of the robbery.
The Court held that the homicide was a direct consequence of the robbery, making the crime a special complex crime of Robbery with Homicide.

4. Aggravating Circumstance
The commission of the crime in the dwelling of the victim was considered an aggravating circumstance, but since the penalty for Robbery with Homicide is already reclusion perpetua to death, and no other aggravating or mitigating circumstances were present, the penalty of reclusion perpetua was correctly imposed.

5. Damages
The Court modified the damages awarded, increasing the civil indemnity, moral damages, and exemplary damages in line with prevailing jurisprudence, and awarded temperate damages in lieu of actual damages due to insufficient receipts.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. The Decision of the Court of Appeals affirming the conviction of accused-appellant Juan Dela Cruz for Robbery with Homicide is AFFIRMED with MODIFICATION in the award of damages. 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
– Plus interest at 6% per annum from finality of judgment until fully paid.

SO ORDERED.