G.R. No. 146805 ; January 16, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. RUEL EUGENIO Y ANGELES and JIMMY TAN Y ABUCAY, appellants.

FACTS

On July 9, 1999, a civilian informer reported to the 14th Regional Narcotics Office in Baguio City that appellants Ruel Eugenio and Jimmy Tan were engaged in selling marijuana. A buy-bust team was formed with PO3 Juan Piggangay as the poseur-buyer. The team coordinated with the Baguio City Police Office. The poseur-buyer and the informer proceeded to Hilltop Road, where the informer introduced Piggangay to the appellants. Piggangay inquired about the price of marijuana per kilo, and Jimmy Tan stated it was P1,000. Piggangay ordered one kilo. The appellants left to get the marijuana from La Trinidad, Benguet. They returned later that afternoon, with Jimmy Tan holding a blue plastic bag, which he handed to Piggangay. Upon checking and confirming the contents were marijuana, Piggangay gave the pre-arranged signal, and the back-up team arrested the appellants. The seized brick of dried marijuana leaves weighed 1,034.5 grams and tested positive for marijuana. Appellants denied the charges, claiming they were vegetable vendors who were arrested without cause while returning from buying vegetables, and that the marijuana was planted. The Regional Trial Court of Baguio City found them guilty beyond reasonable doubt of violating Section 4, Article II of Republic Act No. 6425 , as amended, and sentenced each to reclusion perpetua and a fine of P500,000.

ISSUE

Whether the trial court erred in giving credence to the testimony of the prosecution witnesses and totally disregarding the evidence for the defense.

RULING

The Supreme Court denied the appeal and affirmed the trial court’s decision. The Court held that the prosecution established the guilt of the appellants beyond reasonable doubt. The testimonies of the prosecution witnesses were consistent, unequivocal, and worthy of credence. The defense of frame-up was rejected, as it is easy to contrive and difficult to disprove, and appellants failed to present clear and convincing evidence to overcome the positive identification by the police officers or to prove any ill motive on the part of the arresting team. The presumption of regularity in the performance of official duties by the police officers stood. The Court further ruled that the presentation of the “buy-bust” money in court is not indispensable to the prosecution of illegal drug cases, nor is prior surveillance by the police required; it is sufficient that the elements of the crime are proven by credible witnesses and other evidence. The elements of illegal sale of marijuana—the identity of the buyer and seller, the object and consideration, and the delivery of the drugs—were all proven in this case.