G.R. No. 77756 March 26, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee vs. RENATO MENDOZA JAVIER y TORRES, accused-appellant.

FACTS

Accused-appellant Renato Mendoza Javier y Torres was convicted by the Regional Trial Court of Makati for violating the Dangerous Drugs Act (Republic Act No. 6425) and sentenced to life imprisonment and a fine. The prosecution’s case stemmed from a buy-bust operation on September 11, 1985, in Las Piñas. Acting on a tip, a NARCOM team, with Sergeant Aladano as the poseur-buyer and Barangay Captain De La Cruz (appellant’s cousin) as the informant, conducted the operation. Aladano, introduced by De La Cruz, gave marked money to appellant in exchange for marijuana. Upon receipt, Aladano signaled the team, and appellant was arrested. Forensic tests confirmed the substance was marijuana and that appellant’s hands tested positive for ultraviolet powder used to dust the marked money.
The appellant presented a截然不同的 version, claiming he was arbitrarily arrested while having a snack. He alleged that NARCOM agents planted evidence, demanded money for his release, and later forced him to sign a wrapper containing marijuana while in custody. He also claimed the powder on his hands was applied during this custodial maltreatment. The defense attempted to present testimony regarding an alleged extortion attempt by a certain Pat. Antonio but failed to properly lay the basis for this claim during the direct examination of appellant’s father.

ISSUE

Whether the guilt of the accused-appellant for the illegal sale of marijuana was proven beyond reasonable doubt.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the prosecution’s evidence, primarily the testimonies of the NARCOM agents involved in the buy-bust operation, to be credible and sufficient to establish guilt beyond reasonable doubt. The defense of frame-up and extortion was rejected for lack of credible substantiation. The Court noted the defense failed to establish any improper motive on the part of the arresting officers to falsely implicate the appellant. The procedural lapse during the examination of the defense witness, where the basis for the extortion claim was not laid, weakened the defense’s narrative. The Court also found no merit in the appellant’s argument regarding the timeline of the operation, stating that the nature of NARCOM’s work necessitates readiness, making a two-hour mobilization period reasonable. Furthermore, the Court held that the familial relationship and trust between appellant and Barangay Captain De La Cruz did not prove innocence but merely explained why appellant was unsuspecting. The positive identification by the poseur-buyer, the forensic evidence (the marijuana and the ultraviolet powder on appellant’s hands), and the lack of proven ill motive on the part of the authorities collectively overcame the presumption of innocence.