GR 115304; (July, 1995) (Digest)
G.R. No. 115304 . July 3, 1995.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ROLAND L. MELOSANTOS, accused-appellant.
FACTS
Accused-appellant Roland Melosantos was convicted of selling one kilogram of methamphetamine hydrochloride (shabu) and sentenced to life imprisonment. The prosecution’s case rested on a buy-bust operation conducted on October 10, 1992. SPO1 Jeremias Manlatao testified as the poseur-buyer, claiming Melosantos arrived at a designated Shell gas station, showed the shabu from his car’s trunk, and was arrested after receiving the marked money. The prosecution evidence included the seized drugs, the buy-bust money, and a Joint Affidavit of Arrest.
Melosantos denied the allegations, claiming no buy-bust occurred and that a certain Michael Ty was the actual possessor of the drugs. The defense highlighted critical inconsistencies in the prosecution’s narrative, particularly regarding the roles and testimonies of the arresting officers.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt for the illegal sale of dangerous drugs.
RULING
The Supreme Court REVERSED the conviction and ACQUITTED Roland Melosantos. The prosecution failed to meet the required quantum of proof beyond reasonable doubt due to irreconcilable inconsistencies in the testimonies of its witnesses, which eroded their credibility. A major discrepancy centered on the role of SPO4 Pedro Velasco. SPO1 Manlatao’s testimony and the Joint Affidavit portrayed Velasco as an active participant in the buy-bust operation as a back-up officer. However, Velasco himself testified under oath that he was merely an investigator who arrived after the arrest and had no involvement in the operation itself. The trial court’s attempt to reconcile this by assuming Velasco had a dual assignment was speculative and unsupported by evidence.
Furthermore, Velasco admitted that any admission from Melosantos during custodial investigation was obtained without the assistance of counsel, rendering it inadmissible. The Court emphasized that the prosecution bears the burden of proof, and the presumption of innocence prevails. The constitutional right of the accused cannot be overcome by evidence resting on a shaky foundation, regardless of the gravity of the offense charged. The inconsistencies created reasonable doubt as to the veracity of the alleged buy-bust operation and Melosantos’s participation therein.