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

Ponente: J. PERFECTO

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 commission of the robbery, a struggle ensued, and Dela Cruz fatally stabbed Santos.

The prosecution presented eyewitness Maria Santos, the victim’s wife, who testified that she saw Dela Cruz enter their house, demand money, and stab her husband when he resisted. The defense, however, interposed the defense of alibi, claiming that Dela Cruz was in a different barangay attending a fiesta at the time of the incident. The trial court found the prosecution’s evidence credible and 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 trial court erred in giving credence to the testimony of the eyewitness and in disregarding his alibi. He also contended that the prosecution failed to prove his guilt beyond reasonable doubt.

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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 trial court correctly appreciated the qualifying circumstance of robbery with homicide.

RULING

1. The prosecution proved the guilt of the accused beyond reasonable doubt.

The Supreme Court upheld the conviction. The testimony of eyewitness Maria Santos was found to be clear, consistent, and credible. She positively identified Dela Cruz as the perpetrator and provided a detailed account of the incident. The Court emphasized that positive identification prevails over alibi, especially when the witness had no ill motive to falsely testify against the accused.

2. The defense of alibi is 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 be at the crime scene. Dela Cruz failed to establish the physical impossibility of his presence at the crime scene, as the barangay where he claimed to be was only 30 minutes away by vehicle. Hence, his alibi was correctly rejected.

3. The trial court correctly appreciated the crime as Robbery with Homicide.

The elements of Robbery with Homicide are: (a) the taking of personal property with intent to gain; (b) with violence or intimidation against a person; (c) the robbery being the main purpose and the homicide merely incidental; and (d) the homicide being committed by reason or on occasion of the robbery. All these elements were proven beyond reasonable doubt. The killing occurred during the robbery, and the intent to rob was evident from Dela Cruz’s demand for money.

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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 the crime 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 finality of this judgment until fully paid.

SO ORDERED.