G.R. No. 104399 March 20, 1995
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ANTONIO ALVARADO Y GALON, accused-appellant.

FACTS

Acting on a tip, a buy-bust team was formed with Pat. Jaime Gregorio as the poseur-buyer. Gregorio, accompanied by an informant, went to a specified address in Quezon City to purchase shabu from a certain “Itik” Galon. They met Manuel Sevilla, who left after being told of their intent. Appellant Antonio Alvarado later appeared, stated the drugs were entrusted to him, and after a brief wait, handed three plastic bags of shabu to Gregorio. Gregorio claimed he paid Alvarado with marked money and signaled for the arrest. Alvarado and Sevilla were then apprehended. A laboratory test confirmed the substance was methamphetamine hydrochloride.
The defense presented a starkly different account. Alvarado testified that armed men in plain clothes raided his house without a warrant, fired warning shots, and rounded up the occupants while looking for “Itik.” Failing to find their target, the officers allegedly planted shabu and arrested everyone present. Alvarado’s mother and Manuel Sevilla corroborated this version. The trial court convicted Alvarado based primarily on Gregorio’s testimony, sentencing him to reclusion perpetua and a fine, while acquitting Sevilla.

ISSUE

Whether the prosecution proved the guilt of the accused beyond reasonable doubt for the illegal sale of dangerous drugs.

RULING

The Supreme Court reversed the conviction and acquitted Antonio Alvarado. The Court acknowledged that a conviction can rest on the sole testimony of a poseur-buyer, provided it is clear and convincing. However, the trial court’s assessment of credibility can be overturned if it overlooked significant facts. Here, the prosecution’s case, anchored on Pat. Gregorio’s testimony, was fatally flawed due to material contradictions. During direct examination, Gregorio categorically stated he handed the marked money to Alvarado. Yet, on cross-examination, he admitted he negotiated with and paid Manuel Sevilla. This irreconcilable discrepancy on the crucial act of payment—the very consummation of the sale—created reasonable doubt as to whether Alvarado was indeed the seller. The prosecution failed to present the confidential informant or other corroborative evidence to clarify this contradiction. Consequently, the evidence did not meet the required moral certainty for conviction. The Court also noted the trial court’s error in imposing reclusion perpetua instead of the correct penalty of life imprisonment under the law at the time, but the acquittal rendered this point moot.