G.R. No. 78954 , June 18, 1990
The People of the Philippines, plaintiff-appellee, vs. Arsenio Alfonso y Cawading, defendant-appellant.

FACTS

An information charged Arsenio Alfonso with violating the Dangerous Drugs Act for transporting approximately 2,900 grams of dried marijuana leaves. Prosecution evidence established that on July 30, 1986, Narcom agents, acting on a tip, set up a checkpoint in Tublay, Benguet. They flagged down a bus, inspected luggage, and found a sack marked “14-14-14 compound fertilizer” beside Alfonso. Upon inspection, the sack yielded vegetables and, underneath, a plastic bag containing marijuana. Alfonso claimed ownership of the sack and was arrested. Forensic examination confirmed the substance was marijuana.
The defense presented a different narrative. Alfonso testified he was traveling to inform his brother of their mother’s illness. He claimed a certain Augusta Banghito placed the sack beside him on the bus, instructing him to drop it off at a specified location where someone else would claim it. He asserted he had no knowledge of its illicit contents. His brother Fernando corroborated the story about the family emergency and their activities that day.

ISSUE

The core issue is whether the prosecution proved Alfonso’s guilt for illegal transportation of marijuana beyond a reasonable doubt, specifically whether he had knowledge and conscious possession of the prohibited drugs.

RULING

The Supreme Court affirmed the conviction. The Court found the prosecution’s evidence credible and consistent, establishing that Alfonso was in possession of the sack and that he explicitly claimed ownership when questioned by the agents. This act of claiming the sack is a clear indication of conscious possession. The discovery of marijuana within that sack, which was under his immediate control and dominion on the bus seat, completes the elements of the crime of illegal transportation.
In contrast, the Court found the defense story fabricated and unworthy of belief. Alfonso’s alibi and the claim that the sack belonged to another person were riddled with inconsistencies and illogical sequences, as highlighted by the trial court’s observations of the witnesses’ demeanor. The defense failed to provide a credible explanation for his possession of the sack containing a large quantity of marijuana. The supposed arrangement to deliver the sack for another person, without inquiry or compensation, defied belief and was deemed a mere afterthought to escape liability. Consequently, the trial court’s assessment of credibility, which favored the prosecution witnesses, was upheld. The elements of the crime—illegal transportation and possession of prohibited drugs—were proven beyond reasonable doubt.