G.R. No. 113498. January 16, 1997.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALFREDO BRIONES Y RUVERA, accused-appellant.

FACTS

Accused-appellant Alfredo Briones was charged with the illegal sale of shabu under Republic Act No. 6425. The prosecution’s case rested on a buy-bust operation conducted on March 4, 1993, in Manila. SPO1 Eulalio Alilio acted as the poseur-buyer and testified that he handed a marked P100 bill to Briones in exchange for a plastic packet of shabu. Upon completion of the sale, Alilio gave a pre-arranged signal by placing his hand on Briones’s shoulder, prompting back-up officers PO3 Amorsolo Maravilla and PO3 Roque Blanco to effect the arrest. The marked money and additional packets of shabu were allegedly recovered from Briones.
The defense presented a starkly different version. Briones testified that he was merely waiting for a friend when SPO1 Alilio, whom he recognized from a prior arrest of his friend, suddenly approached and arrested him without any buy-bust transaction occurring. This account was corroborated by defense witnesses Clarita Santiago and Alquin Ormoc, who stated they saw the arrest and that no sale preceded it.

ISSUE

Whether the guilt of the accused-appellant for the illegal sale of dangerous drugs was proven beyond reasonable doubt.

RULING

The Supreme Court REVERSED the conviction and ACQUITTED accused-appellant Alfredo Briones. The acquittal was based on the prosecution’s failure to prove guilt beyond reasonable doubt due to material inconsistencies in the testimonies of the police officers and the resulting failure to establish the crucial element of the corpus delicti—the illicit sale itself.
The legal logic centers on the evaluation of evidence. The testimony of the alleged poseur-buyer, SPO1 Alilio, was critically uncorroborated by his back-up officer, PO3 Maravilla. While Alilio testified to a completed exchange of money and drugs, Maravilla explicitly stated he did not witness any such transaction and did not see any shabu confiscated at the scene. This contradiction directly undermines the narrative of a consummated sale. Furthermore, the Court found the defense’s claim—that the arrest was a frame-up by an officer known to the appellant—to be credible under the circumstances. The presumption of regularity in the performance of official duty cannot prevail over the constitutional presumption of innocence, especially when the prosecution’s evidence is weak and inconsistent. Where the evidence for the prosecution and defense are in equipoise, the scales must tilt in favor of the accused. Consequently, the element of sale was not established with moral certainty, giving rise to reasonable doubt warranting acquittal.