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

Ponente: J. PERFECTO

FACTS

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, the accused, armed with a knife, entered the residence of the victim, Pedro Santos, and forcibly took cash and jewelry. During the robbery, Pedro Santos resisted, and in the ensuing struggle, the accused stabbed him, causing his death.

The prosecution presented an eyewitness, Maria Santos, the victim’s wife, who testified that she saw the accused inside their house and witnessed the stabbing. The defense, on the other hand, interposed the defense of alibi, claiming that the accused was in a different city attending a family gathering at the time of the incident.

The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua. 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 the accused for Robbery with Homicide despite the alleged weakness of the prosecution’s evidence and the strength of the defense of alibi.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction of the accused.

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RATIONALE

1. Credibility of Prosecution Witness
The Court upheld the findings of both the RTC and the CA regarding the credibility of Maria Santos. As the wife of the victim, her testimony was found to be candid, consistent, and given in a straightforward manner. The Court emphasized that findings of trial courts on the credibility of witnesses are accorded great weight and respect on appeal, as they are in a better position to observe the witnesses’ demeanor, conduct, and attitude. No ill motive was proven that would impel her to falsely testify against the accused.

2. Elements of Robbery with Homicide
The Court found all elements of the crime present:
a) The taking of personal property with intent to gain;
b) The taking was with violence or intimidation against persons;
c) The robbery resulted in homicide.
The prosecution successfully established that the accused entered the house, demanded valuables, and killed the victim when he resisted. The killing occurred by reason or on the occasion of the robbery, which is sufficient to constitute the special complex crime.

3. Defense of Alibi
The defense of alibi was correctly rejected by the lower courts. For alibi to prosper, the accused must prove not only that he was somewhere else when the crime was committed but also that it was physically impossible for him to have been at the scene of the crime. The accused failed to establish physical impossibility, as the distance between the crime scene and the place where he claimed to be was not insurmountable within the timeframe. Moreover, alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness.

4. Aggravating Circumstance
The Court noted that the crime was committed in the dwelling of the victim, which is an aggravating circumstance under Article 14 of the Revised Penal Code. However, since the penalty for Robbery with Homicide is already reclusion perpetua to death, and there is no other modifying circumstance, the imposition of reclusion perpetua was proper.

5. Damages
The Court modified the award of damages in line with prevailing jurisprudence. The accused was ordered to pay:
– Civil Indemnity: ₱100,000.00
– Moral Damages: ₱100,000.00
– Exemplary Damages: ₱100,000.00
– Actual Damages (supported by receipts): ₱50,000.00
– Loss of Earning Capacity (computed based on the victim’s age and income): ₱1,200,000.00
All monetary awards shall earn interest at 6% per annum from the finality of the judgment until fully paid.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DENIED. The Decision of the Court of Appeals affirming the conviction of Juan dela Cruz for Robbery with Homicide is AFFIRMED with MODIFICATION as to the award of damages. Accused-appellant is sentenced to suffer the penalty of reclusion perpetua and ordered to pay the heirs of Pedro Santos the amounts specified above.

SO ORDERED.