G.R. No. 83957 ; April 26, 1991
The People of the Philippines, plaintiff-appellee, vs. Danilo Cabanban, defendant-appellant.

FACTS

Danilo Cabanban was convicted for planting and cultivating marijuana, while his six co-accused were acquitted. The prosecution established that on April 15, 1980, police officers, acting on a tip, proceeded to a plantation in La Union. There, they saw Cabanban holding a can, watering or having just watered marijuana plants. Upon seeing the officers, Cabanban attempted to flee but was apprehended. The police took photographs of Cabanban with the plants, uprooted samples, and later secured a chemistry report confirming the substance as marijuana.
At trial, Cabanban denied the charges, claiming he was forced to pose for the pictures at gunpoint and challenging a confiscation receipt as an invalid extrajudicial confession. The trial court rejected his denial and, while agreeing the receipt was inadmissible for being obtained without counsel, convicted him based on the other evidence, sentencing him to life imprisonment and a fine.

ISSUE

Whether the conviction of Danilo Cabanban is supported by sufficient and credible evidence despite alleged inconsistencies in the testimonies of the prosecution witnesses.

RULING

The Supreme Court affirmed the conviction. The Court held that the alleged inconsistencies cited by the appellant—such as minor variances in witnesses’ descriptions of the can he held, who exactly apprehended him, or the precise moment he started to run—were inconsequential and did not undermine the core consistency of the prosecution’s narrative. The Court explained that different witnesses may perceive and recall the same event from varying perspectives, especially during a dynamic incident involving an attempted escape, without their testimonies being fabricated. Such minor discrepancies may even indicate truthfulness rather than rehearsed deception.
The central issue was one of witness credibility, a matter primarily within the trial court’s domain, as it directly observed the witnesses’ demeanor. The trial court found the police officers credible, performing their duty without ill motive. The core facts—that Cabanban was caught at the plantation with the plants and fled—remained substantiated. The Court emphasized that an acquittal cannot be secured by nitpicking over trivial inconsistencies that do not relate to the essential elements of the crime. The evidence sufficiently proved Cabanban’s guilt beyond reasonable doubt for violating the Dangerous Drugs Act.