G.R. No. 107192 November 18, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RODOLFO SALINAS y HERNANDEZ, accused-appellant.

FACTS

Accused-appellant Rodolfo Salinas y Hernandez was charged with violation of Section 15, Article III of Republic Act No. 6425 (The Dangerous Drugs Act of 1972) for the unlawful sale and delivery of Methamphetamine Hydrochloride (shabu). The prosecution evidence, through the testimonies of PO2 Benito Basilio, Jr. and SPO3 Ely Ramos, established that on January 27, 1992, a buy-bust operation was conducted on Vergel St., Pasay City. PO2 Basilio acted as the poseur-buyer and was introduced to Salinas by a civilian informant. Salinas asked how much shabu was wanted; Basilio replied P400 worth and handed over four marked P100 bills. Salinas then handed Basilio a small plastic packet containing a white crystalline substance, which was later confirmed by Forensic Chemist Leslie B. Chambers to be shabu. Upon Basilio’s pre-arranged signal, the buy-bust team arrested Salinas, and the marked money was recovered from him. The accused-appellant pleaded not guilty and claimed he was framed, testifying that he was arrested while buying bread and that police officers attempted to extort money from him. The Regional Trial Court found him guilty and sentenced him to life imprisonment and a fine of P20,000.00.

ISSUE

Whether the alleged contradictions and inconsistencies in the testimonies of the prosecution witnesses are material so as to affect their credibility and whether the prosecution proved the guilt of the accused beyond reasonable doubt.

RULING

The Supreme Court affirmed the decision of the trial court. The alleged contradictions and inconsistencies in the prosecution’s evidence, such as details regarding the surveillance, the designation of the poseur-buyer, the time the team was formed, the number of vehicles used, the arrival time at the scene, and the specifics of the sale transaction, were deemed minor and immaterial. The Court held that the commission of the crime was consummated and clearly established by the credible testimony of the poseur-buyer, PO2 Benito Basilio, Jr., who directly transacted with the accused. The minor inconsistencies were considered badges of truth rather than falsehood. The constitutional presumption of innocence was overcome by proof beyond reasonable doubt. The presumption that official duty was regularly performed by the police officers was applied, as the contrary was not proven. The penalty of life imprisonment and fine were upheld.