G.R. No. 102522 , June 5, 1995
People of the Philippines vs. Judrito Adaya y Balasbas

FACTS

The accused-appellant, Judrito Adaya, was convicted for selling marijuana in violation of the Dangerous Drugs Act. The prosecution’s case stemmed from a buy-bust operation on July 22, 1987. NARCOM agents, acting on a tip, deployed civilian informer Rey Alasaas as a poseur-buyer. Alasaas, provided with marked money, approached Adaya and asked if he had marijuana. Upon Adaya’s affirmative response, Alasaas handed over the marked bills, and Adaya delivered a plastic tea bag. Alasaas then gave the pre-arranged signal, leading to Adaya’s immediate arrest. The substance was later confirmed by the NBI to be marijuana.
Adaya presented a different version, claiming he was merely watching television when NARCOM agents arrived, handcuffed him, and mauled him for ten minutes in the presence of his father and neighbors to extract a confession. He alleged the evidence was planted and the case was a frame-up. The trial court rejected his defense, convicted him, and sentenced him to reclusion perpetua and a fine.

ISSUE

The core issue is whether the prosecution proved Adaya’s guilt for the illegal sale of marijuana beyond reasonable doubt, overcoming his defenses of frame-up, alleged inconsistencies in prosecution testimonies, and denial of the buy-bust operation.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court found the prosecution’s evidence credible and sufficient. The detailed testimonies of Lt. Cantos and the poseur-buyer, corroborated by the physical evidence and the NBI forensic report, established all elements of the illegal sale. The Court dismissed Adaya’s claim of inconsistencies as referring only to a trivial detail about distances, which did not affect the core narrative of the sale.
The defense of frame-up and torture was rejected as a bare allegation. The Court emphasized that such a defense requires strong and convincing evidence. Adaya failed to present any corroborating witness, including his father who allegedly witnessed the mauling, or any medical certificate to substantiate his claims. In contrast, the NARCOM agents enjoyed the presumption of regularity in the performance of duty, with no evidence of improper motive to falsely accuse him.
However, applying the favorable retroactive effect of the amendatory law ( R.A. No. 7659 ), the penalty was reduced. Since the marijuana involved weighed only 1.6261 grams, the proper penalty is within the range of prision correccional. Applying the Indeterminate Sentence Law, the Court imposed an indeterminate sentence of six months of arresto mayor maximum as minimum, to four years and two months of prision correccional medium as maximum. As Adaya had been detained since 1987, he was ordered immediately released.