GR 149872; (March, 2003) (Digest)
G.R. Nos. 149872-73; March 14, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. ROSDIA HAJILI y SAKILAN and NORMINA UNDAY y ALOH, appellants.
FACTS
Appellants Rosdia Hajili and Normina Unday were charged with violating the Dangerous Drugs Act. In Criminal Case No. 16263, they were accused of selling 241.6338 grams of shabu to PO3 Enrique Rivera, a poseur-buyer, for P200,000.00. In Criminal Case No. 16264, they were charged with possession of an additional 4.0859 grams. The prosecution evidence established that a buy-bust operation was conducted on August 23, 1999, in Zamboanga City following a tip and a prior negotiation. PO3 Rivera testified that he and an informant met Hajili, who agreed to sell five “lowest” packs of shabu. During the bust, Rivera gave the marked money to Hajili, who then instructed Unday to retrieve the drugs. Upon Rivera’s pre-arranged signal, the backup team arrested the appellants and recovered the drugs and marked money.
The appellants denied the charges, claiming they were framed. They alleged that police officers forcibly entered their residence without a warrant, arrested them, and planted the evidence. They argued that the buy-bust operation was a sham and that the prosecution failed to prove their guilt beyond reasonable doubt, pointing to alleged inconsistencies in the police testimonies and the lack of prior surveillance.
ISSUE
Whether the guilt of the appellants for the illegal sale and possession of dangerous drugs was proven beyond reasonable doubt.
RULING
Yes. The Supreme Court affirmed the convictions, upholding the trial court’s assessment of the witnesses’ credibility. The Court found the testimonies of the police officers, particularly PO3 Rivera, to be clear, consistent, and credible. Their detailed narration of the buy-bust operation—from the initial negotiation to the arrest and seizure—constituted sufficient proof of the illegal sale. The recovery of the marked money from Hajili and the drugs from Unday’s possession cemented their culpability. The defense of frame-up was rejected for being unsubstantiated and inherently weak, as it was not supported by clear and convincing evidence of any ill motive on the part of the arresting officers. The Court ruled that the minor inconsistencies cited by the defense pertained to trivial details that did not undermine the core narrative of the crime. In drug cases, the credibility of the poseur-buyer is paramount, and his positive identification of the appellants as the sellers prevails over their bare denials. The elements of illegal sale and possession were thus conclusively established, warranting the affirmance of the penalties imposed by the trial court.