GR 102880; (April, 1994) (Digest)
G.R. No. 102880 April 25, 1994
People of the Philippines, plaintiff-appellee, vs. Raul Cruz y Lalaw, accused-appellant.
FACTS
Accused-appellant Raul Cruz y Lalaw was charged with violation of the Dangerous Drugs Act for unlawfully selling and delivering marijuana to Pat. Cesar J. Pineda. The prosecution’s case rested primarily on the testimony of Pat. Pineda, who acted as a poseur-buyer in a buy-bust operation. According to Pineda, on June 23, 1991, he approached Cruz, gave him a marked P20.00 bill, and in return received six sticks of marijuana. Cruz was then arrested, and a search yielded three more sticks and later, dried marijuana leaves were found near his house. The forensic chemist confirmed the substances were marijuana. The defense presented a different account, with Cruz claiming he was a sampaguita vendor who was apprehended, brought to his house where marijuana was allegedly planted, and arrested after he failed to provide information about other suspected drug pushers.
ISSUE
Whether the guilt of the accused-appellant for the crime charged has been proven beyond reasonable doubt.
RULING
The Supreme Court REVERSED and SET ASIDE the judgment of conviction and ACQUITTED accused-appellant Raul Cruz y Lalaw. The Court found that the prosecution failed to establish guilt beyond reasonable doubt due to material inconsistencies in the testimony of the principal witness, Pat. Pineda. These inconsistencies included: (1) a contradiction between his sworn statement (where he claimed Cruz immediately handed over marijuana after receiving the money) and his court testimony (where he stated Cruz went into an alley first before returning with the marijuana); (2) discrepancies regarding whether the marked money was recovered; (3) conflicting accounts on whether the marijuana sticks were marked at the arrest site or at the police station; and (4) inconsistencies in the description of the packaging of the dried marijuana leaves. The Court emphasized that in drug cases, given the potential for abuse in buy-bust operations, the evidence must be scrutinized with extra vigilance. The prosecution’s evidence, being replete with contradictions on material points, did not meet the required standard of proof. The weakness of the defense does not relieve the prosecution of its burden to prove guilt based on the strength of its own evidence.