GR 77588; (May, 1989) (Digest)
G.R. No. 77588. May 12, 1989.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JUNE SANCHEZ y CARMONA, defendant-appellant.
FACTS
The accused, June Sanchez y Carmona, was charged with violating the Dangerous Drugs Act (R.A. No. 6425) for allegedly selling sixteen grams of marijuana in Makati on May 24, 1985. Following a tip from a confidential informant, a police team conducted a buy-bust operation. Sergeant Artemio Serrano acted as the poseur-buyer and, with the informant, negotiated with the accused. After the accused and a companion, Jimmy Mirabueno, left and returned, Mirabueno handed marijuana to Sgt. Serrano. The team then arrested them. Forensic examination confirmed the substance was marijuana.
The accused presented a contrasting version, claiming he was merely waiting for a ride when apprehended by officers who insisted he possessed a firearm, not drugs. He denied knowing Mirabueno or participating in any drug sale. He challenged the prosecution’s evidence, pointing to alleged discrepancies in the police testimonies and the non-presentation of the buy-bust money and the informant.
ISSUE
The core issue is whether the prosecution proved the accused’s guilt for the illegal sale of marijuana beyond reasonable doubt.
RULING
The Supreme Court affirmed the conviction. The Court found the testimonies of the police officers, Sgts. Serrano and Palmero, to be credible and consistent in their material points regarding the buy-bust operation. The alleged discrepancy—whether the accused was first brought to the detachment or to Mirabueno’s house after arrest—was deemed inconsequential and did not undermine the core narrative of the sale. The forensic chemist’s testimony provided conclusive evidence that the substance sold was marijuana.
The Court rejected the defense arguments. The non-presentation of the buy-bust money was not fatal, as the sale was sufficiently established through credible testimonial evidence. The identity of the confidential informant could rightly remain secret for practical reasons of safety and to encourage future cooperation with law enforcement. The claim that a drug pusher would not sell to a stranger was unpersuasive, as the Court recognized that retail sellers often transact with anyone who has the purchase price. The operation constituted a valid entrapment, not an inducement, as the police merely provided an opportunity for the accused to commit an offense he was already predisposed to commit. Therefore, the trial court correctly found the accused guilty beyond reasonable doubt.