G.R. No. 76893 February 27, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO PACO Y TAMAYO, defendant-appellant.

FACTS

The accused, Eduardo Paco y Tamayo, was charged with selling prohibited drugs under the Dangerous Drugs Act. The prosecution evidence established that after a surveillance and a successful test-buy operation in the morning of July 25, 1982, where Sgt. Recto Dacayanan purchased one foil of marijuana from Paco, a buy-bust team was formed. In the afternoon, Sgt. Dacayanan, acting as a poseur-buyer, again approached Paco and bought two more foils of marijuana for marked money. Upon the consummation of the sale, Dacayanan signaled his team, arrested Paco after a brief chase, and recovered the marked bills from his pocket. Chemical analysis confirmed the substances were marijuana.
In his defense, Paco denied the sale. He testified he was merely playing basketball when apprehended, that the marked money was actually taken from his wallet, and that he saw Sgt. Dacayanan holding the marijuana foils before his arrest. He claimed he was forced to admit the crime but refused. The Regional Trial Court convicted him and imposed life imprisonment and a fine.

ISSUE

The core issues were: (1) the admissibility of the marked money and marijuana foils as evidence, and (2) whether the prosecution proved Paco’s guilt beyond reasonable doubt.

RULING

The Supreme Court affirmed the conviction. On the first issue, the Court ruled the evidence was admissible. The marijuana foils were not obtained from an illegal search. The first foil was voluntarily given during the morning test-buy, and the two afternoon foils were the very subject of the sale delivered prior to arrest. The marked bills were seized incident to a lawful arrest. The arrest was valid as it was made after a buy-bust operation, where the accused was caught in flagrante delicto selling marijuana. A warrant was therefore unnecessary.
On the second issue, the Court found the prosecution’s evidence credible and sufficient for conviction. The testimonies of the police officers, particularly the poseur-buyer, were straightforward and consistent, detailing the two transactions. The defense of denial and frame-up was weak and unsubstantiated. The Court upheld the trial court’s assessment of witness credibility, noting no reason to deviate from its findings. The failure of the police to raid a house where Paco allegedly sourced the marijuana did not discredit their operation, as they had no prior basis for a search warrant and acted promptly to apprehend a caught-in-the-act offender. The guilt of the appellant for the crime of selling prohibited drugs was established beyond reasonable doubt.