G.R. No. 150050; June 17, 2004
RUFINO LAPUZ y MENDOZA, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.

FACTS

Petitioner Rufino Lapuz was convicted for selling methamphetamine hydrochloride in a buy-bust operation. The prosecution evidence established that on May 29, 1996, a police team, acting on a tip, conducted an operation in Valenzuela City. PO3 Cesar Pineda acted as the poseur-buyer and was given two marked P100 bills. PO3 Pineda approached Lapuz, handed him the money, and received two plastic sachets of shabu. Upon consummation of the sale, Lapuz attempted to flee but was apprehended. The seized drugs were presented in court.
Lapuz appealed his conviction, arguing before the Supreme Court that the prosecution’s evidence was insufficient. He specifically questioned the probative value of the poseur-buyer’s bare testimony, the adequacy of merely presenting the seized drugs, the accused’s burden to prove police ill motive, and the non-presentation of a logbook containing the serial numbers of the marked money despite a subpoena.

ISSUE

The core issue is whether the prosecution successfully proved the elements of illegal sale of dangerous drugs beyond reasonable doubt based on the presented evidence.

RULING

The Supreme Court denied the petition and affirmed the conviction. The Court held that a conviction for the illegal sale of drugs can rest on the credible testimony of a single witness, the poseur-buyer, provided it establishes the identity of the buyer and seller, the object and consideration, and the delivery and payment. PO3 Pineda’s testimony satisfactorily proved these elements, corroborated by the presentation of the seized drugs in court. Police officers enjoy the presumption of regularity in the performance of their duties, which Lapuz failed to rebut with clear evidence of improper motive or non-performance of duty.
The Court found no merit in Lapuz’s specific arguments. The poseur-buyer’s inability to recall the exact serial numbers of the marked money did not discredit his testimony; it was a minor detail that did not negate the core transaction. The marked money itself was identified and offered in evidence. The logbook was merely corroborative, and its non-production, despite a subpoena, did not constitute willful suppression of material evidence, as the presumption of suppression applies only to evidence that is not merely corroborative. The trial court’s findings on witness credibility, affirmed by the Court of Appeals, are entitled to great respect. The evidence established Lapuz’s guilt beyond reasonable doubt.