G.R. No. 84951 November 14, 1989
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. SUSANA NAPAT-A y MACABIO, accused-appellant.

FACTS

The accused-appellant, Susana Napat-a, was convicted by the Regional Trial Court of Baguio City for selling marijuana and sentenced to life imprisonment. The prosecution’s case stemmed from a buy-bust operation on February 3, 1985. Acting on a tip, a team led by Captain Emmanuel Manzano was formed, with CIC Leo Quevedo acting as the poseur-buyer. Quevedo, introduced by an informant, met Napat-a at a public market and negotiated to buy three kilos of marijuana at P800 per kilo. Napat-a then led Quevedo and the informant to Brookside, Baguio City, where she retrieved a brown carton box and handed it to Quevedo. Upon Quevedo’s pre-arranged signal, backup officers Pat. Maximiano Peralta and A2C Serafin Artizona rushed in and arrested Napat-a. The box was later confirmed by a forensic chemist to contain marijuana.
In her defense, Napat-a, a vegetable vendor, claimed she was framed. She testified that she was merely waiting for a ride when she witnessed another vendor, Naty Doguiwen, hand a box to a man before fleeing upon the approach of two other men. These men then arrested Napat-a instead. She admitted signing a receipt for the seized property during custodial investigation but later contested its admissibility, claiming her constitutional rights were violated.

ISSUE

The core issue is whether the trial court erred in convicting the accused-appellant despite her defenses of frame-up, the non-presentation of the poseur-buyer and informant, and the alleged inadmissibility of her signed receipt for the seized drugs.

RULING

The Supreme Court affirmed the conviction. The legal logic is anchored on the credibility of the prosecution’s evidence and the presumption of regularity in the performance of official duties. The Court found Napat-a’s defense of frame-up unpersuasive, characterizing it as a common but unsubstantiated allegation. The non-presentation of the deceased poseur-buyer, Quevedo, and the informant was not fatal to the case. The testimony of the two arresting officers, Peralta and Artizona, who witnessed the transaction, provided direct and positive evidence of the sale. While Artizona did not see the actual handover, Peralta’s clear testimony that he saw Napat-a deliver the box to Quevedo was given credence.
Regarding the signed receipt (Exhibit J), the Court ruled it was admissible. Napat-a admitted during trial that she was assisted by counsel from the IBP Legal Aid Office when she signed it, and the Investigation Report (Exhibit I) confirmed she was informed of her rights. Thus, her right against self-incrimination was not violated. Finally, the subsequent loss of the physical drug exhibits did not undermine the prosecution’s case. The forensic chemist had testified about them in court, they were properly described in the records, and the defense had cross-examined the witnesses on these exhibits. The positive identification of Napat-a as the seller, supported by credible testimony, established her guilt beyond reasonable doubt.