G.R. No. L-64262 March 16, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CELERINO VIOLA y ARLENTE, accused-appellant.

FACTS

The prosecution’s case, established through the testimonies of PC officers, was that on October 5, 1981, a team from the Constabulary Anti-Narcotics Unit (CANU) acted on a tip about drug pushing at Pedro Gil, Manila. Officers Lt. Miguel Marcelo and Sgt. Abelardo Lasam positioned themselves near Arellano High School. They witnessed their confidential informant hand a marked P50 bill to the accused, Celerino Viola. Viola left and returned after approximately thirty minutes. As he was handing nine Mogadon tablets to the informant, the officers arrested him. Laboratory analysis confirmed the tablets were Mogadon, a regulated drug. Viola, in a written statement, admitted guilt and even led officers to a location to identify a supplier named “Jojo,” who was not found.
The defense presented a starkly different version. Viola testified he was a student at Arellano University when an acquaintance, “Boy Toothpick,” gave him P50 and instructed him to buy Mogadon, with the assurance that CANU agents would follow to apprehend the seller. Claiming fear of being mauled if he refused, Viola took a tricycle to Makati, bought the tablets without seeing any officers tailing him, and was arrested upon his return. He alleged his confession was extracted by having him sign a blank paper under a promise of release.

ISSUE

The core issue is whether the trial court erred in convicting the appellant based on the prosecution’s evidence, thereby rejecting the defense of instigation and finding guilt beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. The resolution hinged fundamentally on the credibility of witnesses, a domain where the trial court’s assessment is accorded great respect. The Court found the defense narrative unconvincing and illogical. Viola’s claim that he proceeded to buy the drugs out of fear, despite seeing no law enforcement following him as promised, undermined his credibility. In contrast, the prosecution evidence clearly established a consummated sale: Viola received money, left to procure the drugs, and returned to deliver them. The act constituted entrapment, not instigation, as the criminal intent originated from the appellant himself. The minor inconsistency between officers regarding the exact duration of Viola’s absence was deemed immaterial to the core facts of the sale. The Court also noted the absence of any proven improper motive for the officers to falsely implicate the appellant. The non-presentation of the confidential informant did not weaken the case, as the testimonies of the apprehending officers were direct, credible, and sufficient to establish guilt. The trial court committed no error in giving greater weight to the prosecution’s evidence and finding no reasonable doubt as to Viola’s violation of the Dangerous Drugs Act.