G.R. No. 103396 March 3, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARSENIO DEOCARIZA y BALLE, defendant-appellant.

FACTS

The accused-appellant, Arsenio Deocariza y Balle, was charged with violating Section 4, Article II of R.A. 6425 (the Dangerous Drugs Act) for allegedly selling and distributing dried marijuana leaves. The prosecution’s case rested primarily on the testimony of Staff Sgt. Dande Deocampo, who acted as a poseur-buyer in a buy-bust operation on May 17, 1990, in Iloilo City. Sgt. Deocampo testified that, based on a tip about rampant drug selling in the area, he was designated as the buyer. Upon arriving at the location, he was approached by the accused, who inquired if he was waiting for someone. Sgt. Deocampo expressed a desire to buy “damo” (marijuana), and the accused offered to sell a quarter of a plastic pack for P50.00. After handing over a marked P50 bill, Sgt. Deocampo received a plastic pack from the accused, which was later confirmed by forensic chemist Capt. Zenaida Sinfuego to contain marijuana. The accused was then arrested, and the marked money was recovered from him.
The accused presented a different version. He testified that he was at the location to ask his sister for money to buy asthma medicine. While purchasing candies in a store, three persons frisked him, mauled him, and then brought him to Camp Delgado, where he was further beaten to force a confession. He denied selling marijuana and claimed the evidence was “planted.” His testimony was corroborated by Marcos Palle, who witnessed the arrest without any prior conversation, and his sister, Thelma Teodosio, who stated the NARCOM agents ransacked her house after the arrest.
The trial court convicted the accused, giving full faith to Sgt. Deocampo’s testimony and sentencing him to life imprisonment and a fine.

ISSUE

Whether the trial court erred in convicting the accused based on the uncorroborated and allegedly improbable testimony of the prosecution witness, thereby violating the accused’s constitutional rights and failing to prove guilt beyond reasonable doubt.

RULING

The Supreme Court REVERSED the trial court’s decision and ACQUITTED the accused. The Court found that the prosecution failed to prove guilt beyond reasonable doubt. Key reasons include:
1. The testimony of Sgt. Deocampo was seriously flawed and improbable. The buy-bust operation was initiated on a vague tip with no specific suspect, name, or description, and no prior surveillance was conducted. The Court found it improbable that the entire sale and arrest transpired within three minutes of the officer’s arrival.
2. The prosecution’s case relied solely on the uncorroborated testimony of Sgt. Deocampo. While not illegal, such testimony requires careful scrutiny, especially when contradicted by other evidence. The defense presented corroborating witnesses whose testimonies were not inherently improbable.
3. The evidence presented was insufficient. The prosecution failed to present the original marked money, offering only a photocopy, and did not present other participating NARCOM agents, like Sgt. Bonete, to corroborate the story.
4. The Court emphasized the need for extra vigilance in drug cases due to the potential for abuse in anti-narcotics operations, such as planting evidence. The presumption of regularity in the performance of official duty alone could not overcome the reasonable doubt created by the circumstances.
The demands of proof beyond reasonable doubt were not met.