GR 109998; (August, 1994) (Digest)
G.R. No. 109998 August 15, 1994
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MANUEL CAÑEJA Y ILAS, accused-appellant.
FACTS
The accused, Manuel Cañeja, was charged with the illegal sale of shabu under the Dangerous Drugs Act. The prosecution’s case rested on a buy-bust operation where an informant, Joel Ubago, acted as a poseur-buyer. Ubago testified that he approached the accused’s residence, gave him a marked P100 bill, and received a foil packet containing methamphetamine hydrochloride. Police officers, positioned nearby, arrested Cañeja upon Ubago’s signal. The defense presented a starkly different version, claiming Cañeja was merely playing darts when Ubago and an acquaintance, “Onchie,” called him. They then allegedly grabbed him, and arriving policemen forced him into a taxi. The defense asserted the arrest was a frame-up due to a prior quarrel with “Onchie.” The trial court convicted Cañeja and sentenced him to life imprisonment.
ISSUE
The core issue is whether the prosecution successfully proved the guilt of the accused beyond reasonable doubt for the illegal sale of a dangerous drug. A subsidiary issue involves the correct penalty to be imposed following recent amendments to the law.
RULING
The Supreme Court affirmed the conviction but modified the penalty. The Court found the prosecution’s evidence credible and sufficient. The testimonies of the poseur-buyer and the apprehending officer were consistent and detailed, establishing the consummated sale. The defense of frame-up was rejected for being unsubstantiated and inherently weak, as the accused failed to prove any ill motive on the part of the police officers to falsely implicate him. The Court upheld the trial court’s assessment of witness credibility. Regarding the penalty, the Court applied Republic Act No. 7659 , which amended the Dangerous Drugs Act. The law now prescribes penalties based on the quantity of the drug. Since the shabu weighed only 0.0958 gram, the imposable penalty under the amended law is prision correccional. Applying the Indeterminate Sentence Law, the Court modified the sentence to an indeterminate penalty ranging from six months of arresto mayor as minimum to six years of prision correccional as maximum.