G.R. No. 87884 November 4, 1992
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO CRUZ y DELA ROSA, accused-appellant.

FACTS

The accused-appellant, Antonio Cruz y Dela Rosa, was charged with violating Section 4, Article II of Republic Act No. 6425 (Dangerous Drugs Act) for allegedly selling, delivering, and giving away twelve (12) grams of dried marijuana fruiting tops in Taytay, Rizal, on October 3, 1985. The prosecution’s case was based on a buy-bust operation conducted by Sgt. Edison Balatucan and Lt. Jose, along with two unnamed informers. The operation was initially dispatched to Barangay Sta. Ana, but the accused accompanied the team to Barangay San Isidro after the original target was “negative.” The prosecution presented only the testimonies of the two military officers. After their testimonies, the defense filed a Motion to Dismiss by Way of Demurrer to Evidence, arguing that guilt was not proven beyond reasonable doubt. The trial court initially allowed the accused to present evidence but later rectified this and submitted the case for resolution based solely on the prosecution’s evidence. The trial court convicted the accused and sentenced him to reclusion perpetua and a fine of P20,000.00, despite noting significant inconsistencies in the prosecution witnesses’ testimonies. The accused appealed.

ISSUE

Whether the guilt of the accused-appellant was proven beyond reasonable doubt.

RULING

No. The Supreme Court reversed the trial court’s decision and acquitted the accused-appellant. The Court found that the prosecution failed to establish guilt beyond reasonable doubt due to material inconsistencies and contradictions in the testimonies of the sole witnesses, Sgt. Balatucan and Lt. Jose. These inconsistencies pertained to crucial details such as who recovered the marijuana (from the accused’s pocket or handed by the accused), who initially approached the accused (the sergeant or the informer), and the location of the operation (Sta. Ana or San Isidro). The trial court improperly acted as an advocate for the prosecution by attempting to reconcile these irreconcilable testimonies instead of evaluating the evidence impartially. The defense was precluded from presenting evidence, including proof of improper motive, due to the trial court’s application of the demurrer rule. The Court emphasized that conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense, and that the constitutional presumption of innocence must prevail when the evidence is insufficient. While police officers in buy-bust operations are entitled to a presumption of regularity, the Court must be vigilant against the possibility of evidence being “planted,” especially given the grave nature of the offense and the severe penalties involved. The prosecution’s evidence was deemed insufficient to overcome the presumption of innocence.