GR 84450; (February, 1991) (Digest)
G.R. No. 84450 ; February 4, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. GLORIA UMALI y AMADO AND SUZETH UMALI y AMADO, defendants-appellants.
FACTS
Accused Gloria Umali was charged with violating the Dangerous Drugs Act for selling marijuana. The prosecution’s case originated from a police investigation into the drug dependency of a minor, Pierre Pangan. Seeking the source, police enlisted the help of detention prisoner Francisco Manalo, who had a pending drug case. Police provided Manalo with marked money, which he used to purchase two foils of marijuana from Gloria Umali. Manalo returned with the drugs and gave a statement. Based on his affidavit, police secured a search warrant for Umali’s residence. The search yielded the marked bills from Umali’s person and sixteen foils of marijuana from her kitchen. At trial, the court convicted Gloria Umali based on this evidence, sentencing her to reclusion perpetua.
ISSUE
The core issue is whether the conviction of Gloria Umali for selling marijuana is supported by credible evidence and obtained through legal means, particularly regarding the admissibility of the evidence seized.
RULING
The Supreme Court affirmed the conviction. The Court held that the evidence, including the testimony of Manalo and the police, the marked money, and the seized marijuana, was admissible and sufficient to prove guilt beyond reasonable doubt. The defense’s claim of an illegal search was rejected because the seizure was conducted under a validly issued search warrant. The Court emphasized the presumption of regularity in the performance of official duties by law enforcers, absent any proof to the contrary. The testimony of Manalo, a detained informant, was deemed credible as his cooperation was motivated by a desire for assistance with his other cases, not by an arrangement concerning his drug charge to which he had already pleaded guilty. The discovery of the marked bills on Umali’s person directly corroborated the sale. The Court modified the penalty by imposing a fine of Twenty Thousand Pesos (P20,000.00) in addition to life imprisonment, as mandated by the applicable law.