G.R. No. 198314 , September 24, 2014
People of the Philippines, Plaintiff-Appellee, vs. Richard Guinto y San Andres, Accused-Appellant.

FACTS

The accused-appellant, Richard Guinto, was charged with Illegal Sale of Dangerous Drugs under Section 5, Article II of R.A. No. 9165 . The prosecution’s case was based on a buy-bust operation conducted on January 20, 2004, in Pasig City. PO1 Melvin Jesus S. Mendoza acted as the poseur-buyer and testified that he bought two plastic sachets of shabu from Guinto using marked money. The defense interposed denial, claiming Guinto was illegally arrested while cooking at home with his family, and that the police attempted to extort money from his wife. The prosecution presented PO1 Mendoza, PO1 Michael Familara, and PO2 Richard Noble as witnesses. However, their testimonies contained several inconsistencies on material points: who gave the buy-bust money (SPO3 Matias vs. P/Insp. Esguerra); the pre-arranged signal (raising hand vs. scratching the nape); the time the asset arrived and the team proceeded to the target area; how long they waited for the accused (two hours vs. 15-20 minutes); and crucially, the number of sachets sold (PO1 Mendoza said two, while PO1 Familara testified that PO1 Mendoza told him it was one). The defense witnesses (Guinto, his wife Jane, and son John Mark) consistently testified about the illegal arrest at their home. The RTC and the Court of Appeals convicted Guinto, but the Supreme Court reviewed the case on appeal.

ISSUE

Whether the prosecution proved the guilt of the accused-appellant for illegal sale of dangerous drugs beyond reasonable doubt.

RULING

The Supreme Court REVERSED the decisions of the lower courts and ACQUITTED Richard Guinto. The prosecution failed to prove his guilt beyond reasonable doubt. The Court held that the identity of the corpus delicti (the illegal drug) was not established with moral certainty due to irreconcilable inconsistencies in the testimonies of the prosecution witnesses on material points. Specifically, the conflicting accounts regarding the number of plastic sachets sold (one vs. two) directly tainted the very identity of the dangerous drug, which is vital to sustain a conviction. These inconsistencies, coupled with discrepancies on other significant details like the source of the buy-bust money, the pre-arranged signal, and the timeline of the operation, eroded the credibility of the prosecution’s narrative and defeated the presumption of regularity in the performance of official duties. The failure to conclusively establish the identity of the corpus delicti is fatal to the prosecution’s case.