G.R. No. 83260 ; April 18, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. JUAN DE LA CRUZ y GONZALES and REYNALDO BELTRAN y ANIBAN, accused-appellants.

FACTS

Accused-appellants Juan de la Cruz and Reynaldo Beltran were charged with the illegal sale of marijuana. The prosecution’s evidence established that a buy-bust operation was conducted on May 4, 1987, in Manila. Acting on a tip, a team of NARCOM agents deployed P/Pfc. Adolfo Arcoy as a poseur-buyer. Arcoy, accompanied by an informant, approached Juan de la Cruz and expressed intent to buy marijuana. De la Cruz then instructed Reynaldo Beltran, who retrieved a foil of marijuana from his pocket and handed it to Arcoy. Upon confirming the substance, Arcoy gave a pre-arranged signal, leading to the arrest of both accused. The marked money was recovered from De la Cruz, and two additional foils of marijuana were seized.
The defense presented a starkly different version. Accused Juan de la Cruz claimed he was bedridden due to illness at his residence and was subjected to a warrantless search and arrest. Accused Reynaldo Beltran asserted he was arrested while playing pool, having been pointed out by the informant, and denied any participation in a drug sale. The trial court found the prosecution’s narrative credible and convicted both accused. During the appeal, Juan de la Cruz died, leading to the dismissal of the case against him, leaving Reynaldo Beltran as the sole appellant.

ISSUE

The core issue is whether the conviction of appellant Reynaldo Beltran for the illegal sale of marijuana is valid, considering his challenges to the legality of the buy-bust operation and the credibility of the prosecution’s evidence.

RULING

The Supreme Court affirmed the conviction. The Court upheld the legality and constitutionality of the buy-bust operation as a valid form of entrapment. In such operations, law enforcers are not instigators but merely present an opportunity for the commission of a crime by an already predisposed offender. The arrest of Beltran was deemed lawful as it was effected during the consummation of the crime, falling under a valid warrantless arrest. The subsequent seizure of the marked money and additional drugs was likewise justified as incidental to a lawful arrest.
The Court deferred to the trial court’s assessment of witness credibility, noting the absence of any ill motive on the part of the police officers to fabricate charges. Appellant’s bare allegations of police corruption and quota systems were unsupported by evidence. The non-presentation of the civilian informant as a witness did not weaken the prosecution’s case, as the testimony of the apprehending officers who directly witnessed the transaction was sufficient to establish guilt beyond reasonable doubt. The elements of illegal sale of a prohibited drug—the identity of the buyer and seller, the object of the sale, the consideration, and the delivery—were convincingly proven through Arcoy’s straightforward testimony.