G.R. No. 110357 . August 17, 1994.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CARLOS TRANCA Y ARELLANO, accused-appellant.

FACTS

Accused-appellant Carlos Tranca y Arellano was charged with the illegal sale of methamphetamine hydrochloride (shabu) under R.A. No. 6425 . The prosecution evidence established that on May 6, 1991, a buy-bust team was formed after an informant reported that a certain “Jon-Jon” was selling shabu in Makati. Sgt. Jose Latumbo acted as the poseur-buyer, using a marked P100 bill dusted with fluorescent powder. At the target area, the informant introduced Latumbo to the accused. After a brief conversation, the accused handed over a package of shabu in exchange for the marked money. Upon Latumbo’s pre-arranged signal, the team arrested the accused, who later voluntarily surrendered an additional plastic bag of shabu and the marked bill. Forensic tests confirmed the substances were shabu and that fluorescent powder was found on the money and the accused’s person.
The accused denied the charges, claiming he was framed. He testified that police officers forcibly entered his home, demanded money, and arrested him without cause. He presented his sister as a witness to corroborate his story. The trial court found the prosecution’s version credible and convicted the accused, sentencing him to life imprisonment and a fine.

ISSUE

The core issue is whether the trial court erred in convicting the accused based on the evidence presented and in imposing the penalty of life imprisonment.

RULING

The Supreme Court affirmed the conviction but modified the penalty. The Court upheld the trial court’s assessment of credibility, ruling that the testimonies of the police officers involved in the buy-bust operation were clear, consistent, and credible. The defense of frame-up was rejected for being unsubstantiated and inherently weak, especially when weighed against the straightforward narrative of the prosecution, which was corroborated by physical evidence—the marked money, the positive forensic findings on the seized drugs, and the presence of fluorescent powder on the accused. The Court reiterated that the absence of the informant as a witness is not fatal to the prosecution’s case.
Regarding the penalty, the Court applied the amendments introduced by R.A. No. 7659 , which reclassified penalties based on the quantity of shabu involved. Since the total weight of the confiscated shabu was only 1.10 grams, the imposable penalty under the law is prision correccional. Applying the Indeterminate Sentence Law, the Court modified the sentence to an indeterminate penalty ranging from six (6) months of arresto mayor as minimum to six (6) years of prision correccional as maximum. The conviction was thus affirmed with this modification to the penalty.