GR 77582; (December, 1989) (Digest)
G.R. No. 77582, December 19, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. LORENZO SAYANG-OD, accused-appellant.
FACTS
The accused, Lorenzo Sayang-od, along with Ben Bula-oy, Baltazar Caranay, and Juanito Carreon, were charged with violating the Dangerous Drugs Act for allegedly conspiring to sell approximately six kilos of dried marijuana leaves to a poseur-buyer, Sgt. Edmund Hufana, in Naguilian, La Union. The prosecution’s case, built on a “buy-bust” operation, presented multiple PC witnesses who testified that Sayang-od arrived carrying a sack of marijuana and engaged in price haggling before the arrest. The defense presented a contrasting narrative, claiming the marijuana belonged to an at-large co-accused, Brando Flores, and that Sayang-od and the others were merely present at the scene without involvement in any drug transaction.
The trial court acquitted Bula-oy, Caranay, and Carreon, finding the prosecution failed to prove conspiracy beyond reasonable doubt. However, it convicted Sayang-od of the crime, sentencing him to life imprisonment and a fine. The court rejected the defense’s claim that Flores was the sole owner of the marijuana, instead crediting the prosecution’s evidence that positively identified Sayang-od as the carrier of the prohibited drug.
ISSUE
Whether the trial court erred in convicting accused-appellant Lorenzo Sayang-od of violating Section 4, Article II of the Dangerous Drugs Act.
RULING
The Supreme Court affirmed the conviction. The legal logic rests on the evaluation of evidence and the finality of acquittals. The Court found the testimonies of the prosecution witnesses, particularly Sgt. Hufana, to be clear, convincing, and straightforward, positively identifying Sayang-od as the person who delivered the sack of marijuana during the buy-bust operation. The defense’s claim that Flores was the real owner was deemed an unsuccessful attempt to shift blame, which did not negate the strong evidence against Sayang-od.
While the Supreme Court expressed the view that the trial court should have convicted all four accused due to evidence suggesting a collective cover-up—which it considered indicative of conspiracy—it was constrained by the constitutional rule on double jeopardy. The acquittal of the three co-accused had become final and could no longer be reviewed or overturned. Consequently, only Sayang-od’s conviction was subject to appeal. Finding no reason to disturb the trial court’s factual findings and credibility assessments as they pertained to Sayang-od, the Supreme Court upheld the judgment. However, noting the apparent inequity where Sayang-od alone bore full liability, the Court strongly recommended executive clemency in his favor.