GR 101333; (March, 1993) (Digest)
G.R. No. 101333 March 2, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LUIS SAMSON Y CAMON and GIL CAMPORAZO, accused-appellants.
FACTS
Accused-appellants Luis Samson and Gil Camporazo were charged with violating Section 8 of R.A. No. 6425 (Dangerous Drugs Act) for allegedly selling and possessing twelve (12) sticks of dried marijuana leaves in La Carlota City on March 9, 1987. They pleaded not guilty. The prosecution’s case rested primarily on the testimony of Patrolman Rolando Zamora. He testified that while on duty, an informant told him about a marijuana sale. He gave the informant a marked P20 bill to conduct a buy-bust. Zamora followed and witnessed from about 30 meters away as the informant gave money to Samson, and Camporazo handed over marijuana. After the transaction, Zamora apprehended both, recovering the marked money from Samson and rolled marijuana leaves from Camporazo. A forensic chemist confirmed the substances were marijuana. The defense presented a different version: the accused were drinking tuba after work when Zamora suddenly searched them, found nothing, but then claimed to have recovered contraband from his own pocket, and arrested them without cause.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt for the sale and possession of marijuana.
RULING
The Supreme Court REVERSED and SET ASIDE the trial court’s decision and ACQUITTED accused-appellants Luis Samson and Gil Camporazo. The prosecution failed to establish guilt beyond reasonable doubt. The testimony of the lone prosecution witness, Patrolman Zamora, was deemed unreliable due to material contradictions (e.g., initially stating nothing was found on Camporazo, then claiming marijuana was recovered) and suspicious details (e.g., admitting he carried marijuana for comparison). The Court found the buy-bust operation questionable as there was no prior surveillance, no coordination with superiors, and the critical witness—the informant-poseur buyer—was never presented in court. This failure to present the informant, who had personal knowledge of the transaction, created a fatal gap in the prosecution’s evidence, giving rise to the presumption that his testimony would be adverse if produced. The accused’s denial, coupled with the serious doubts cast on the prosecution’s narrative, warranted acquittal on grounds of reasonable doubt.