G.R. No. L-73399 November 28, 1986
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAMON ABEDES Y SALGADO, defendant-appellant.

FACTS

Ramon Abedes y Salgado was convicted by the Regional Trial Court of Quezon City for violating the Dangerous Drugs Act ( R.A. No. 6425 , as amended) and sentenced to life imprisonment and a fine. The prosecution evidence established that on October 2, 1984, based on a tip, Anti-Narcotics Command operatives set up an entrapment. Sergeant Angelito Manalo, posing as a buyer, was introduced to Abedes by an informer. Abedes provided one tea bag of marijuana in exchange for a marked ten-peso bill. Upon the pre-arranged signal, arresting officers apprehended Abedes, recovered the marked money from his waist, and, after he was informed of his rights, he voluntarily surrendered an additional piece of marijuana cake from his residence. Forensic tests confirmed the substances were marijuana.
The defense presented a starkly different version. Abedes claimed he was forcibly taken from his pigpen by four armed men, handcuffed, and framed. He alleged he was coerced to sign a receipt, threatened for money, and that no marijuana was recovered from him. He denied consenting to any search and claimed the prosecution’s narrative was fabricated.

ISSUE

The core issues were: (1) whether the trial court’s factual findings convicting Abedes were supported by evidence, and (2) whether the penalty of life imprisonment was excessive.

RULING

The Supreme Court affirmed the conviction and the penalty. The Court found the trial court’s factual conclusions fully supported by the evidence. It systematically rejected Abedes’s arguments attacking minor alleged inconsistencies in the prosecution’s case. The Court held that the identification of the marked money did not solely depend on recording its serial number, as treating it with powder was a valid alternative method. The non-presentation of Abedes’s shorts or the confidential informer was within the prosecution’s discretion and did not weaken its case, which was built on the direct, positive, and consistent testimonies of the arresting officers.
The Court emphasized that Abedes’s defense amounted to nothing more than a bare denial, which cannot prevail over the positive identification by prosecution witnesses. Regarding the penalty, the Court ruled it was precisely within the range mandated by Section 4 of the Dangerous Drugs Act, as amended, which prescribes life imprisonment to death and a fine for the sale of prohibited drugs. Citing precedent, the Court stated that a drug pusher “deserves no mercy,” as the crime is a grave societal ill. The appeal was denied, and the decision was affirmed with a minor correction to delete the parenthetical “30 years” from the life imprisonment term.