G.R. No. L-66885 February 27, 1987
People of the Philippines, plaintiff-appellee, vs. Reynaldo Acelajado, defendant-appellant.

FACTS

On November 30, 1982, Herminigildo Caraan was having lunch at a carinderia in Siniloan, Laguna, when the accused, Reynaldo Acelajado, approached and offered to sell him marijuana. Caraan purchased one plastic bag of marijuana for ten pesos. Later, while inside the Relan Theater, Caraan rolled the marijuana into cigarettes. He was subsequently frisked by Pat. Rolando Ambojia, who confiscated three sticks of marijuana cigarettes. Caraan was taken to police headquarters, where he gave a statement identifying Acelajado as the seller. Forensic analysis by the NBI confirmed the confiscated items were marijuana.
The defense presented an alibi, claiming Acelajado was in Malabon, Metro Manila, from November 29, 1982, and stayed with an aunt for a week. However, this aunt was not presented in court to corroborate his testimony. The defense also presented testimonies from a barangay captain and a police commander, suggesting Caraan implicated Acelajado out of revenge for a prior quarrel. The trial court convicted Acelajado of violating Section 4 of the Dangerous Drugs Act and sentenced him to reclusion perpetua and a fine.

ISSUE

The core issue is the credibility of the prosecution witness, Herminigildo Caraan, versus the alibi and denial presented by the accused.

RULING

The Supreme Court affirmed the conviction. The ruling hinges on the well-established principle that factual findings of the trial court, particularly on witness credibility, are accorded great weight and respect. The trial judge is in the optimal position to observe witness demeanor and assess testimonial candor. The Court found no compelling reason to overturn the trial court’s assessment that Caraan was a credible witness. His testimony was clear, positive, and straightforward regarding the illegal sale.
The defense’s claim of a vendetta motive was deemed uncorroborated and trivial, insufficient to explain a false charge carrying a severe penalty. The testimonies of the defense witnesses on this alleged motive were correctly dismissed as hearsay. Furthermore, the defense of alibi was inherently weak and unsubstantiated. Acelajado’s failure to present his alleged host in Malabon to corroborate his whereabouts critically undermined his claim. An alibi cannot prevail over the positive identification by a credible prosecution witness. The prosecution successfully proved all elements of the illegal sale of a prohibited drug beyond reasonable doubt.