GR 91161; (December, 1991) (Digest)
G.R. No. 91161 , December 17, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JEROME HONRADA y JOBEN, accused-appellant.
FACTS
The prosecution’s case, led by Pfc. Benny Iglesias, was that a buy-bust operation was conducted against accused-appellant Jerome Honrada. Iglesias acted as the poseur-buyer, using a marked ten-peso bill to purchase dried marijuana fruiting tops from Honrada at a pool hall in Pasig. Upon receiving the wrapped marijuana, Iglesias gave a pre-arranged signal, arrested Honrada, and recovered the marked money from his pocket. The forensic chemist confirmed the substance was marijuana. The defense presented a starkly different version. Honrada testified he was casually apprehended by police officers while having a snack at a store, told he was being summoned by a police major, and then brought to the station where he was falsely charged. This account was corroborated by the store owner, Totoy Tumambing, a Lupong Tagapamayapa Kagawad, who testified the encounter was casual, no search was conducted, and no contraband was seen in Honrada’s possession at the scene.
ISSUE
The core issue is whether the prosecution proved Honrada’s guilt for the illegal sale of marijuana beyond a reasonable doubt, given the conflicting narratives of the incident.
RULING
The Supreme Court reversed the conviction and acquitted Honrada. The ruling hinged on the failure of the prosecution’s evidence to overcome the constitutional presumption of innocence. The Court found the lone testimony of Pfc. Iglesias regarding the buy-bust transaction insufficient and unreliable. His credibility was undermined by inconsistencies, such as contradictions with another police officer on when the marked money was initialed. More critically, his testimony was directly contradicted not only by the accused but also by the impartial testimony of Kagawad Tumambing, who had no motive to falsely testify for the accused. Tumambing’s account, which depicted a casual apprehension without any overt drug transaction or immediate recovery of evidence, cast serious doubt on the prosecution’s story. While police officers enjoy a presumption of regular performance of duty, this presumption cannot prevail over the stronger presumption of innocence when the prosecution’s narrative is convincingly challenged. The corroborated defense created reasonable doubt as to whether the alleged sale ever occurred, warranting acquittal.