G.R. No. 101663 November 4, 1992
People of the Philippines, plaintiff-appellee, vs. Eric F. Timtiman, accused-appellant.

FACTS

An information was filed accusing Eric Timtiman of violating Section 4, Article II of Republic Act 6425, as amended (The Dangerous Drugs Act), for the unlawful sale, delivery, and giving away of two tea bags of dried marijuana leaves (2.53 grams) and three sticks of marijuana cigarettes in Tanay, Rizal, on September 5, 1990. The prosecution evidence, as summarized by the trial court, consisted of the testimony of Forensic Chemist P/Lt. Julita T. De Villa, who confirmed the specimens were positive for marijuana; Sgt. Norberto Macaraeg, who acted as poseur-buyer and testified that he bought the marijuana from Timtiman with three P10 bills and then arrested him; and C1C Nonato Esquilon, who acted as backup and apprehended Timtiman based on Macaraeg’s instruction. The Regional Trial Court convicted Timtiman and sentenced him to life imprisonment and a fine.
The defense version, also summarized by the trial court, presented Timtiman, his uncle Renato Concepcion, and his girlfriend Angelita San Juan. They testified that on that date and time, they were at the Midway Restaurant to discuss Timtiman’s plan to elope with San Juan. They claimed that a commotion occurred involving other persons at the restaurant, and Timtiman was mistakenly pointed out and arrested by Macaraeg and Esquilon without having engaged in any drug transaction. Timtiman asserted he had no prior criminal record.

ISSUE

Whether the prosecution proved the guilt of the accused for the illegal sale of marijuana beyond a reasonable doubt.

RULING

The Supreme Court REVERSED and SET ASIDE the decision of the Regional Trial Court. The appellant, Eric Timtiman, was ACQUITTED on grounds of reasonable doubt and ordered immediately released unless detained on another charge.
The Court found the prosecution’s evidence insufficient to establish guilt beyond a reasonable doubt. Key inconsistencies and deficiencies were noted: 1) The testimony of the poseur-buyer, Sgt. Macaraeg, was uncorroborated by his backup, C1C Esquilon, who did not witness the alleged sale and only acted on Macaraeg’s instruction to arrest Timtiman. 2) The defense presented a credible alternative narrative of the events, showing that the inculpatory facts were capable of an explanation consistent with innocence. 3) The prosecution failed to present the three ten-peso bills used as marked money in the buy-bust operation. Citing People v. Mendoza, the Court held that in cases where the accused is alleged to have received the money and was immediately apprehended, the marked money is a material item of evidence to prove a “transactional relationship.” Its absence, under these circumstances, created reasonable doubt. The Court emphasized that the constitutional presumption of innocence prevails over the presumption of regularity in the performance of official duties when the evidence does not establish moral certainty of guilt.