G.R. No. 101313 July 5, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLITO USON Y ESGUERRA, alias “JUN PONGGI”, accused-appellant.

FACTS

On May 29, 1990, accused-appellant Carlito Uson y Esguerra was charged with violating Section 15, Article III of Republic Act No. 6425 (Dangerous Drugs Act) for allegedly selling and delivering 0.02 gram of methamphetamine hydrochloride (shabu) on May 24, 1990, in Pasig, Metro Manila. The prosecution evidence, primarily from Patrolman Raul Casino, sought to establish that a buy-bust operation was conducted based on a tip from a barangay councilman. According to Casino, after a surveillance on May 23, 1990, he was introduced to appellant as a buyer, and a transaction was arranged for 8:00 P.M. that evening at the house of a certain Rolly Concepcion. The alleged sale and arrest occurred at 12:15 A.M. on May 24, 1990, after Casino handed a marked P100 bill to appellant in exchange for shabu wrapped in aluminum foil. Appellant, however, denied the accusation. He testified that he was at a birthday celebration at the Concepcion house until about 11:00 P.M. on May 23, 1990, when he and his friends were arrested by Pat. Casino’s team and immediately detained at the Pasig Police Station, making the alleged 12:15 A.M. sale impossible. His version was corroborated by defense witness Marissa Ortega. The Regional Trial Court convicted appellant and sentenced him to life imprisonment and a fine. Appellant appealed, challenging the credibility of the prosecution witnesses and the admission of evidence.

ISSUE

Whether the prosecution proved beyond reasonable doubt the guilt of accused-appellant Carlito Uson for the illegal sale of a regulated drug.

RULING

The Supreme Court REVERSED and SET ASIDE the judgment of conviction and ACQUITTED accused-appellant Carlito Uson y Esguerra. The Court found that the prosecution failed to prove his guilt beyond reasonable doubt. The testimony of the main prosecution witness, Pat. Raul Casino, was replete with significant inconsistencies and improbabilities. These included contradictions between his sworn statement and his court testimony regarding the details of the entrapment, an unexplained failure to arrest appellant during an alleged afternoon drug sale, an improbable four-hour surveillance despite a pre-arranged meeting place, and an inability to recall the name of a key asset. The Court also noted the prosecution’s failure to present corroborating witnesses from the buy-bust team or to submit the marked money as evidence. The defense’s consistent and corroborated alibi that appellant was already in custody at the time of the alleged sale further weakened the prosecution’s case. The Court emphasized that the prosecution must rely on the strength of its own evidence and not on the weakness of the defense, and that given the grave penalty and the possibility of abuse in drug operations, the testimony of the sole poseur-buyer required careful scrutiny and corroboration, which was lacking. Appellant was ordered immediately released unless detained for another lawful cause.