G.R. No. 81520 February 21, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. NEIL TEJADA, accused-appellant.

FACTS

The accused-appellant, Neil Tejada, was convicted by the Regional Trial Court of Caloocan City for violating the Dangerous Drugs Act. The prosecution evidence established that on August 7, 1987, a NARCOM team conducted a buy-bust operation on Libis Gochico Street, Caloocan City, based on a tip from a confidential informant. S/Sgt. Rodelito Obice acted as the poseur-buyer, using marked money. The informant introduced Obice to Tejada in front of a sari-sari store. Tejada asked how much marijuana was needed, and upon being told P150.00, he left briefly, returned with a brown paper containing marijuana in a plastic bag, and handed it to Obice. After Obice gave a pre-arranged signal, other agents moved in and arrested Tejada. The seized substance was confirmed by forensic examination to be marijuana.
The defense presented a different version, claiming Tejada was merely waiting for a ride when suddenly apprehended by individuals who later identified themselves as NARCOM agents. He alleged that the arrest was a frame-up and that the agents attempted to extort money from his father in exchange for his release, which his father could not afford. The trial court rejected this defense and found Tejada guilty beyond reasonable doubt, sentencing him to reclusion perpetua.

ISSUE

The core issue is whether the trial court erred in convicting the accused based on the prosecution’s evidence and in applying the presumption of regularity in the performance of official duty by the arresting officers.

RULING

The Supreme Court affirmed the conviction. The Court emphasized the well-settled rule that the trial court’s findings on the credibility of witnesses are entitled to great respect, as the trial judge has the direct opportunity to observe their demeanor. The appellant failed to show any fact or circumstance that was overlooked and which would substantially alter the case’s outcome. The Court found no merit in the contention that the drug transaction near a sari-sari store was incredible. The circumstance that a sale is not conducted in absolute secrecy does not negate its occurrence, especially when the buyer is ready and willing to complete the transaction quickly.
Regarding the defense of frame-up and extortion, the Court ruled that the presumption of regularity in the performance of official duty by the NARCOM agents was not successfully rebutted. The allegation of extortion, described as a standard defense in drug cases, was unsupported by any formal complaint or report to higher authorities by the appellant’s father. The delay in delivering the appellant to judicial authorities was explained by the procedural steps following arrest, such as laboratory examination and documentation. The Court found no proof of improper motive on the part of the agents. Consequently, the guilt of the appellant for the illegal sale of marijuana was established beyond reasonable doubt.