G.R. No. 81332 , April 25, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALLAN RODRIGUEZ Y TEVES, accused-appellant.

FACTS

The accused-appellant, Allan Rodriguez y Teves, was charged with violating Section 4, Article II of R.A. 6425 (The Dangerous Drugs Act) for allegedly selling and distributing marijuana. The prosecution evidence established that on June 2, 1987, a police team, acting on a tip, conducted surveillance at a specified address in Makati. They observed the appellant emerge from a house, approach a tricycle, and later return to hand “a suspicious stuff of a cigarette” to the tricycle driver, Enrico Bacod, who in turn gave something to the appellant. The police immediately apprehended both men. A search yielded two plastic bags of suspected marijuana leaves from the appellant and three sticks of suspected marijuana cigarettes from Bacod. Forensic examination confirmed the substances were marijuana. The defense stipulated to the authenticity and findings of the police and forensic reports.
At trial, the appellant denied the charges, claiming the items were planted. He argued the scenario was implausible, contending he would not risk a life sentence for a small transaction in front of his own home with a stranger. The Regional Trial Court convicted him, sentencing him to life imprisonment and a fine. The appellant appealed, questioning the credibility of the prosecution’s narrative and evidence.

ISSUE

Whether the prosecution proved beyond reasonable doubt that the accused-appellant is guilty of selling and distributing marijuana.

RULING

Yes, the Supreme Court affirmed the conviction. The Court found the testimonies of the police officers credible and entitled to the presumption of regularity in the performance of official duty, absent any proof of ill motive. The defense’s mere denial, being negative and self-serving, could not prevail over the positive and categorical declarations of the prosecution witnesses who testified on affirmative acts. The Court rejected the appellant’s argument that the act was improbable. Citing precedent, it ruled that drug pushing is a crime that can be committed quickly and even in public view, which may sometimes serve to camouflage the illicit act. The lack of marked money was not fatal to the prosecution’s case, as the presentation of the prohibited drug itself was sufficient. The agreement and the physical act of delivering the marijuana cigarettes constituted the crime of sale, distribution, or giving away of a prohibited drug. The stipulations by the defense conclusively established the chain of custody and the nature of the seized items as marijuana. Therefore, all elements of the violation were proven beyond reasonable doubt.