GR 86172; (March, 1991) (Digest)
G.R. No. 86172 ; March 4, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BENJAMIN PERALTA DE GUZMAN, accused-appellant.
FACTS
Accused-appellant Benjamin de Guzman, a chicharon vendor, was convicted by the Regional Trial Court of Bulacan for selling marijuana in violation of the Dangerous Drugs Act and sentenced to life imprisonment. The prosecution’s case rested primarily on the testimony of NARCOM Sgt. Ruben Bazar. Bazar testified that a buy-bust operation was conducted on December 7, 1987, in Baliwag, Bulacan. Sgt. Efren Querubin acted as the poseur-buyer using a marked P50 bill. Bazar, positioned ten meters away, saw Querubin and an informant approach de Guzman but did not witness the actual transaction. Upon Querubin’s pre-arranged signal, the team arrested de Guzman, recovered the marked money, and confiscated a plastic bag later confirmed to contain marijuana. De Guzman signed a Receipt of Property Seized.
De Guzman denied the charges, claiming he was arbitrarily arrested, manhandled, and forced to sign the receipt under duress. Two defense witnesses corroborated the forceful arrest. The trial court convicted de Guzman, giving credence to the presumption of regularity in the performance of official duty and noting his failure to protest the arrest or present medical evidence of torture.
ISSUE
Whether the prosecution evidence is sufficient to prove de Guzman’s guilt for selling marijuana beyond reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted de Guzman on the ground of reasonable doubt. The Court emphasized that a conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. Sgt. Bazar’s testimony was critically insufficient. From his vantage point ten meters away, he did not witness the actual sale—he neither saw the delivery of marijuana nor the payment. The testimony of the poseur-buyer, Sgt. Querubin, was essential to establish the consummation of the sale, yet the prosecution inexplicably failed to present him. This failure created a fatal gap in the evidence.
Furthermore, the Receipt of Property Seized, signed by de Guzman, was deemed inadmissible. It constituted a custodial admission made without the assistance of counsel and without the required warnings, violating constitutional rights. De Guzman’s alleged submissiveness during arrest and his prior reputation as a drug dealer were irrelevant and could not compensate for the prosecution’s deficient evidence. The constitutional presumption of innocence prevails when the prosecution’s case cannot stand on its own merits.