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 took cash and jewelry valued at ₱50,000. During the robbery, Pedro Santos was stabbed and killed.

The prosecution presented an eyewitness, Maria Reyes, a neighbor who testified that she saw dela Cruz fleeing the scene with a bloodied knife. The defense, however, interposed the defense of alibi, claiming that dela Cruz was in a different city attending a family reunion at the time of the incident. The trial court found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua without eligibility for parole, and 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 guilt beyond reasonable doubt and that the trial court erred in giving credence to the testimony of the sole eyewitness.

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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. On the proof of guilt beyond reasonable doubt.
The Court ruled that the prosecution successfully proved the guilt of the accused beyond reasonable doubt. The testimony of eyewitness Maria Reyes was clear, consistent, and credible. She positively identified dela Cruz as the perpetrator, and her testimony was corroborated by physical evidence, including the recovery of the knife with the victim’s blood. The defense failed to show any ill motive on the part of the witness to falsely testify against the accused.

2. On the defense of alibi.
The defense of alibi is inherently weak and cannot prevail over the positive identification of the accused by a credible witness. 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 scene of the crime. Dela Cruz failed to establish physical impossibility, as the location of the family reunion was only a few hours away from the crime scene. Hence, the defense of alibi must fail.

3. On the penalty imposed.
Robbery with Homicide under Article 294 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 is correct. However, the Court modified the damages awarded in line with prevailing jurisprudence, increasing the amounts for civil indemnity, moral damages, and exemplary damages, and adding temperate damages.

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DISPOSITIVE PORTION

WHEREFORE, the appeal is DISMISSED. The Decision of the Regional Trial Court finding accused-appellant Juan dela Cruz GUILTY of Robbery with Homicide is AFFIRMED with MODIFICATION. Accused-appellant is sentenced to reclusion perpetua and ordered to pay the heirs of Pedro Santos the following amounts:

– ₱100,000 as civil indemnity;
– ₱100,000 as moral damages;
– ₱100,000 as exemplary damages; and
– ₱50,000 as temperate damages.

All monetary awards shall earn interest at the rate of six percent (6%) per annum from the finality of this Decision until fully paid.

SO ORDERED.