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, Dela Cruz, armed with a knife, entered the residence of Pedro Santos in Quezon City, forcibly took cash and jewelry valued at ₱50,000, and in the course of the robbery, stabbed Pedro Santos, causing his death.

During trial, the prosecution presented an eyewitness, Maria Santos (the victim’s wife), who testified that she saw Dela Cruz, whom she recognized as a former neighbor, stab her husband and ransack their bedroom. The defense, on the other hand, interposed the defense of alibi, claiming that Dela Cruz was in his hometown in Bulacan at the time of the incident, attending a fiesta. The defense presented two witnesses, friends of Dela Cruz, who corroborated his presence at the fiesta.

The Regional Trial Court (RTC) of Quezon City, Branch 90, found Dela Cruz guilty beyond reasonable doubt of Robbery with Homicide. The court gave full credence to the eyewitness identification by Maria Santos, noting her clear and consistent testimony, and rejected the defense of alibi for being weak and unsubstantiated. Dela Cruz was sentenced to reclusion perpetua and ordered to pay civil indemnity, moral damages, and exemplary damages to the heirs of the victim.

On appeal, the Court of Appeals (CA) affirmed the RTC decision in toto. Hence, this appeal before the Supreme Court.

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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 over the positive identification by an eyewitness.
3. Whether the penalty imposed is correct.

RULING

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

The Supreme Court upheld the findings of the lower courts. The positive identification by Maria Santos, who knew Dela Cruz as a former neighbor, was clear, categorical, and consistent. She had no ill motive to falsely testify against him. The Court emphasized that positive identification, when credible and categorical, prevails over alibi and denial.

2. The defense of alibi cannot prevail over positive identification.

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 crime scene. Dela Cruz failed to establish the physical impossibility of his presence. Bulacan is not so far from Quezon City as to make it impossible for him to have traveled to and from the crime scene on the same day. The testimonies of his witnesses were also deemed insufficient to overturn the positive identification.

3. The penalty imposed is correct.

Robbery with Homicide under Article 294(1) of the Revised Penal Code is punishable by reclusion perpetua to death. In the absence of any aggravating or mitigating circumstances, the penalty of reclusion perpetua was correctly imposed by the lower courts. The award of damages was also affirmed, with modifications in accordance with prevailing jurisprudence to include temperate damages and adjust the amounts for civil indemnity and moral damages.

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DISPOSITIVE PORTION

WHEREFORE, the Decision of the Court of Appeals is AFFIRMED with MODIFICATION. Accused-Appellant Juan Dela Cruz is found GUILTY beyond reasonable doubt of the crime of Robbery with Homicide and is sentenced to suffer the penalty of Reclusion Perpetua. He is ordered to pay the heirs of Pedro Santos the following amounts:

₱100,000.00 as civil indemnity;
₱100,000.00 as moral damages;
₱100,000.00 as exemplary damages; and
₱50,000.00 as temperate damages.

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.