G.R. No. 86219 , June 14, 1990
The People of the Philippines, plaintiff-appellee, vs. Romeo Olivares and Wilfredo Reolo y Regondoia, defendants. Romeo Olivares, appellant.

FACTS

The prosecution’s evidence established that on July 28, 1986, NARCOM operatives in Legazpi City, acting on a tip, secured a search warrant and planned a buy-bust operation targeting appellant Romeo Olivares. A NARCOM informant, provided with a marked P20 bill, proceeded to Olivares’s billiard hall in Guinobatan, Albay. NARCOM agent Riza Galvan positioned himself about ten meters away. The informant met co-accused Wilfredo Reolo at the entrance, handed him the marked money, and Reolo then gave it to Olivares. Olivares entered his adjacent residence, returned after five minutes, and handed the informant a plastic packet. Upon the informant’s pre-arranged signal, Galvan arrested Olivares and Reolo, retrieving the packet which was later confirmed to contain marijuana. A subsequent search of Olivares’s residence, conducted in the presence of barangay officials, yielded two tin cans containing more marijuana leaves and seeds, and the marked bill was recovered from an attache case.
The defense presented a starkly different version, alleging that armed men barged into Olivares’s home, planted the marijuana evidence, and subjected him to physical abuse and extortion. He claimed the entire operation was a frame-up and that his signatures on the property receipt and arrest report were coerced. The trial court rejected this narrative, finding the prosecution’s evidence credible, and convicted Olivares of violating the Dangerous Drugs Act. He appealed, challenging the credibility of the prosecution witnesses and the validity of his arrest and the search.

ISSUE

The core issue is whether the prosecution proved beyond reasonable doubt that Romeo Olivares unlawfully sold and possessed marijuana.

RULING

The Supreme Court affirmed the conviction. The Court found the prosecution’s evidence, particularly the testimony of NARCOM agent Galvan, to be credible, positive, and categorical. Galvan clearly witnessed the transaction from a short distance in a well-lighted area: he saw the marked money change hands to Reolo and then to Olivares, observed Olivares enter his house and return with an item, and saw that item—the marijuana packet—given to the informant. Minor discrepancies in the testimony, such as the exact number of operatives or the precise timing of handing over the marked money, were deemed inconsequential to the core facts of the sale. The recovery of additional marijuana and the marked money from Olivares’s residence further corroborated his guilt. The defense of frame-up was rejected for being unsupported by evidence and failing to show any plausible motive for the NARCOM agents to falsely implicate Olivares in a serious crime. The concatenation of circumstances—the prior intelligence, the secured warrant, the witnessed sale, the immediate arrest, and the subsequent discovery of more contraband—collectively established Olivares’s guilt beyond reasonable doubt for the sale and possession of marijuana.