G.R. No. 101315 May 12, 1993
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MIGUEL L. DELA CRUZ y LIBUCAN, accused-appellant.

FACTS

The Anti-Narcotics Unit of the San Juan Police Station received reports that Miguel dela Cruz was selling shabu. A buy-bust operation was planned for September 12, 1990. Patrolman Cesar Turingan, acting as the poseur-buyer, was provided with two marked one-hundred peso bills, on which he wrote his initials “CBT.” The serial numbers of the bills were recorded in the police blotter prior to the operation. Turingan, accompanied by other officers including Corporal Jaime Blanco, went to dela Cruz’s house on Santa Lucia Street. Turingan approached dela Cruz and asked to buy two decks of shabu. Dela Cruz accepted the marked money, went inside his house, and returned with two plastic bags containing white crystalline substance, which he handed to Turingan. Turingan then arrested dela Cruz and retrieved the marked money. The substance was later confirmed by forensic analysis to be methamphetamine hydrochloride (shabu). Dela Cruz was charged with violating Section 15, Article III of Republic Act No. 6425, as amended. At trial, dela Cruz and his mother presented a different version, claiming he was framed by the police, who forcibly took his wallet and money, found no shabu, but arrested him anyway. The Regional Trial Court convicted dela Cruz, sentencing him to life imprisonment and a fine. He appealed, arguing through the Public Attorney’s Office that the trial court erred in crediting the prosecution’s witnesses, in applying the presumption of regularity in the performance of official duty, in not finding the search illegal, and in finding him guilty beyond reasonable doubt.

ISSUE

Whether the Regional Trial Court erred in convicting accused-appellant Miguel dela Cruz of illegal sale of shabu beyond reasonable doubt.

RULING

The Supreme Court affirmed the decision of the Regional Trial Court. The Court found no merit in the appeal. It held that the selling of prohibited drugs to strangers in public places is a common occurrence and not absurd, as drug pushers often sell to anyone with money, regardless of familiarity. The Court cited previous rulings that such transactions can happen anywhere and are often completed quickly. The alleged discrepancy in the recorded serial numbers of the marked money (PM760674 recorded as PM60674 and JU45557 recorded as JU4557) was deemed a clerical error and did not undermine the prosecution’s evidence, as testimonial and documentary evidence confirmed the recording was done prior to the operation. The Court found the defense of “frame-up” unsubstantiated and easy to concoct. It upheld the trial court’s assessment of the credibility of the prosecution witnesses and the evidence presented. Therefore, the conviction was affirmed.