G.R. No. 87607 October 31, 1990
The People of the Philippines, plaintiff-appellee, vs. Romeo Dela Cruz y Meda, accused-appellant.

FACTS

Accused-appellant Romeo Dela Cruz y Meda was charged with the illegal sale of marijuana under Republic Act No. 6425. The prosecution’s case rested on a buy-bust operation conducted by the Pasay City Police. Patrolman Pedro Serafico, acting as a poseur-buyer, testified that on September 11, 1987, he approached a group of men, including the appellant, at a street corner. He handed a twenty-peso bill to one of the men, who gave it to Dela Cruz. Appellant left briefly and returned to hand Serafico two foils of marijuana, leading to his immediate arrest. The substance was later confirmed by an NBI forensic chemist to be marijuana. Supporting police officers corroborated Serafico’s testimony on the operation and arrest.
The defense presented a different version. Appellant denied the sale, claiming he was forcibly grabbed by police officers in plain clothes who compelled him to point out a known peddler named “Itik.” A defense witness, Orlando Miranda, testified that the actual seller was a man named “Berto,” not the appellant. The trial court rejected the defense’s narrative, convicted Dela Cruz, and sentenced him to life imprisonment and a fine.

ISSUE

The core issue is whether the trial court erred in convicting the appellant based on the prosecution’s evidence, specifically in crediting the buy-bust operation as a valid entrapment and rejecting the defense of instigation and mistaken identity.

RULING

The Supreme Court affirmed the conviction. The Court meticulously distinguished between entrapment and instigation, noting that instigation occurs when law enforcers induce an otherwise innocent person to commit a crime, making them co-principals. In contrast, entrapment involves merely providing an opportunity to capture a lawbreaker already engaged in criminal activity. The evidence showed no inducement; Serafico merely offered to buy, and appellant voluntarily completed the sale. The Court found the police narrative straightforward and credible, with no evidence of improper motive to falsely accuse the appellant.
Regarding the defense of mistaken identity, the Court found the testimony of defense witness Miranda unreliable. It defied logic that police, conducting a targeted buy-bust, would arrest the wrong person while allowing the alleged actual seller, “Berto,” to escape. The Court deferred to the trial court’s superior position to assess witness credibility, noting no substantial reason to overturn its findings. The police officers were presumed to have performed their duties regularly. The penalty of life imprisonment and a fine was correctly imposed under the applicable law.