GR 86641; (April, 1991) (Digest)
G.R. No. 86641; April 26, 1991
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ERIC ANSING y CABANBAN, defendant-appellant.
FACTS
The accused-appellant, Eric Ansing, was convicted by the Regional Trial Court of Pasig for selling marijuana in violation of the Dangerous Drugs Act and sentenced to reclusion perpetua with a fine. The prosecution evidence established that on October 5, 1987, a police buy-bust team conducted an entrapment operation in Pasig based on a tip. Patrolman Isidro Mariano acted as the poseur-buyer and approached Ansing, who agreed to sell P20.00 worth of marijuana. Ansing left briefly, returned with a brown packet containing the substance, and handed it to Mariano in exchange for a marked bill. Upon Mariano’s signal, the team arrested Ansing and recovered the marked money from his pocket. Forensic analysis confirmed the substance was marijuana.
The defense presented a flat denial, claiming Ansing was arbitrarily arrested without a warrant while having a snack near a store. He alleged he was only informed of the drug charge at the police station and was even slapped by an officer. The trial court found the prosecution’s version credible and convicted him.
ISSUE
Whether the alleged inconsistencies in the testimonies of the prosecution witnesses are fatal to the case, thereby negating the conviction of the accused-appellant.
RULING
The Supreme Court affirmed the conviction as modified, changing the penalty to life imprisonment. The Court ruled that the alleged inconsistencies raised by the appellant—such as minor variances in the description of the marijuana’s color (dark brownish vs. green), its form (dried leaves vs. flowering tops), and its wrapping (brown packet vs. plastic bag)—are inconsequential. The Court reiterated the doctrine that minor inconsistencies in the narration of witnesses do not detract from their essential credibility, as long as their testimonies are coherent and believable on the material points. Such inaccuracies may even indicate truthfulness, as perfect recall is not expected.
The Court found no ill motive on the part of the arresting officers, who were presumed to have performed their duties regularly. The positive identification of Ansing by Mariano during the well-lit transaction was upheld. The Court deferred to the trial judge’s assessment of witness credibility, noting his advantage in observing demeanor. Consequently, the guilt of the accused-appellant was established beyond reasonable doubt.