GR 94313; (September, 1991) (Digest)
G.R. No. 94313 September 30, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO COMO y VALENZUELA, alias “ANDO,” accused-appellant.
FACTS
On October 25, 1989, a team from the Narcotics Command conducted a buy-bust operation in Batangas City based on information that accused-appellant Reynaldo Como was selling marijuana. Sergeant William Manglo acted as the poseur-buyer, accompanied by a confidential informant who introduced him to Como as a friend wanting to buy P20.00 worth of marijuana. Upon meeting, Como left, returned with eight sticks of marijuana cigarettes, and handed them to Manglo in exchange for the marked money. Manglo then signaled the backup team, who arrested Como, recovered the marked bills from him, and confiscated the marijuana.
The defense presented a different version. Como claimed he was resting at home when the Narcom agents suddenly pulled him out, handcuffed him, and brought him to their office. He alleged the charge was fabricated by an informant, “Tuding,” after a dispute over fake jewelry. He further claimed he was forced to sign a receipt for the seized items. The Regional Trial Court convicted Como of violating the Dangerous Drugs Act and sentenced him to life imprisonment.
ISSUE
Whether the trial court erred in convicting the accused-appellant based on the credibility of the prosecution witnesses and the evidence presented.
RULING
The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of witness credibility, emphasizing that the trial judge is in the best position to evaluate testimonial evidence firsthand. The prosecution successfully established all elements of the illegal sale of marijuana: the identity of the buyer and seller, the object and consideration, and the delivery of the drugs. The detailed and consistent testimonies of the Narcom agents on the buy-bust operation were deemed credible and sufficient for conviction.
The Court rejected the defense’s claim of frame-up, noting it was unsubstantiated and a common defense in drug cases. It also dismissed the argument that the poseur-buyer and accused knew each other, ruling that such prior acquaintance is immaterial to the consummation of the sale. Finally, the Court found any alleged irregularity in the signing of the receipt for the seized items inconsequential, as the conviction was firmly based on the overwhelming independent evidence of the buy-bust operation, not on any extrajudicial confession. The penalty was affirmed with the clarification that “life imprisonment” is not legally equivalent to reclusion perpetua.