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. Upon opening, it contained a handwritten note, a plastic sachet of white crystalline substance (later confirmed as 0.0944 gram of shabu), and rolled aluminum foil. Caparas testified that accused-appellant, a fellow inmate, gave him the note and sachet to deliver to another inmate, Frederick Cua. The seized items were subsequently marked, inventoried, and photographed in the presence of required witnesses.
In his defense, accused-appellant denied the charges. He claimed he was in his cell at the time and was later summoned to the warden’s office where he was informed of the accusations. He refused to sign the inventory report, asserting 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 the prosecution’s failure to prove his guilt beyond reasonable doubt. For a conviction of Attempted Illegal Sale, 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 that the identities of the buyer and seller were not established with moral certainty. The case did not involve a typical buy-bust operation with a designated poseur-buyer. The alleged buyer, inmate Frederick Cua, was never presented in court to corroborate the intended transaction. The sole evidence linking accused-appellant was the testimony of Caparas, a co-inmate, regarding the source and destination of the drugs. The handwritten note, while suggestive, was not conclusive proof of a sale as it did not unequivocally identify the parties or the terms. It merely contained instructions and did not name a specific seller or buyer.
The Court emphasized that the conviction rested heavily on Caparas’s uncorroborated claim. Without further evidence concretely identifying accused-appellant as the seller and Cua as the buyer, the element of identities remained unproven. The presumption of innocence must prevail when the evidence fails to meet the required quantum of proof. Consequently, the Court reversed the decisions of the lower courts and ordered the immediate release of accused-appellant unless he is detained for another lawful cause.