GR 104284; (June, 1994) (Digest)
G.R. No. 104284 . June 14, 1994.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RHODORA SULIT Y MONASTERIAL, accused-appellant.
FACTS
Accused-appellant Rhodora Sulit y Monasterial was convicted by the Regional Trial Court of Manila for selling 0.084 grams of methamphetamine hydrochloride (shabu) in violation of Section 15, Article III of R.A. No. 6425 , as amended. She was sentenced to life imprisonment and a fine of P20,000. The case stemmed from a buy-bust operation on February 7, 1991, where Pat. Arturo Buenaobra acted as poseur-buyer. According to the prosecution, Buenaobra approached Sulit, gave her a marked P100 bill, and received a deck of shabu. Sulit then re-entered her house, prompting the police to chase her, where they found two other individuals, Roberto Lacanilao and Ricardo Garcia, inside. Lacanilao was allegedly holding an aluminum foil with shabu, and Garcia was found with a marijuana cigarette. Sulit pleaded not guilty, claiming the buy-bust was fabricated and that the police attempted extortion. The trial court acquitted her co-accused (Lacanilao, Garcia, and Rodolfo Loza) due to insufficient evidence or reasonable doubt but convicted Sulit based solely on Buenaobra’s testimony. The trial court erroneously stated that Sulit did not testify, though she had testified and denied the allegations.
ISSUE
Whether the trial court erred in convicting accused-appellant Rhodora Sulit of illegal sale of shabu based on the evidence presented.
RULING
The Supreme Court REVERSED the trial court’s decision and ACQUITTED accused-appellant Rhodora Sulit. The Court found material inconsistencies and improbabilities in the prosecution’s evidence, particularly in the testimony of Pat. Buenaobra. Key points include:
1. Buenaobra testified that the buy-bust was based on reports of “selling of drugs,” but on cross-examination, he admitted the information specifically referred only to “selling of marijuana,” not shabu.
2. The prosecution’s evidence was inconsistent regarding the marked evidence (Exhibit B-a), with Buenaobra identifying it as the shabu from Sulit, while pre-trial records referred to it as specimens from other cases.
3. The Court found it improbable that Sulit would sell shabu to a stranger without any introduction or that Buenaobra, as poseur-buyer, would not arrest her immediately upon receipt of the shabu.
4. The trial judge who rendered the decision did not hear the witnesses testify, thus his assessment of credibility was less reliable.
Given these doubts, the prosecution failed to prove guilt beyond reasonable doubt. Sulit was ordered released unless detained for another lawful cause.