GR 250908; (November, 2020) (Digest)
G.R. No. 250908, November 23, 2020
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. ARIEL QUIÑONES Y LOVERIA, ACCUSED-APPELLANT.
FACTS
This case stemmed from an Information charging accused-appellant Ariel Quiñones with Illegal Sale of Dangerous Drugs. The prosecution alleged that on June 14, 2015, Jail Officer Niel Romana, while conducting a roll call at the Camarines Norte Provincial Jail, frisked inmate Rogelio Caparas and recovered from him a small piece of paper sealed with tape containing a plastic sachet of shabu and a handwritten note. Caparas testified that accused-appellant gave him the items to deliver to another inmate, Frederick Cua. The seized substance tested positive for methamphetamine hydrochloride.
In his defense, accused-appellant denied the charges, claiming he was in his cell when summoned and that he refused to sign the inventory report as he was not the owner of the seized items. The Regional Trial Court convicted him of the lesser crime of Attempted Illegal Sale of Dangerous Drugs, which the Court of Appeals affirmed, giving credence to Caparas’s testimony and finding compliance with the chain of custody rule.
ISSUE
Whether or not accused-appellant is guilty beyond reasonable doubt of Attempted Illegal Sale of Dangerous Drugs.
RULING
No. The Supreme Court acquitted accused-appellant due to reasonable doubt. For a conviction of Attempted Illegal Sale of Dangerous Drugs, the prosecution must prove the identities of the buyer and seller, the object, and the consideration, alongside the commencement of the sale by overt acts not reaching completion due to an external cause.
The Court found the identities of the buyer and seller unproven. The sole evidence implicating accused-appellant as the seller was the uncorroborated testimony of Caparas, a co-inmate. The handwritten note, while referencing a transaction, did not name accused-appellant as the source. Critically, the intended buyer, Frederick Cua, was never presented to confirm the alleged sale or his identity as the buyer. The prosecution failed to establish that Cua was the intended recipient or that there was any agreement between him and accused-appellant. Without this essential link, the element of a consummated or attempted sale between a specific buyer and seller remains speculative. The presumption of innocence prevails over the weak evidence presented.