GR 86975; (March, 1991) (Digest)
G.R. No. 86975; March 18, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MARLON SALCEDO y SISON, accused-appellant.
FACTS
The accused-appellant, Marlon Salcedo, was convicted by the Regional Trial Court of Manila for selling a teabag of dried marijuana flowering tops in violation of the Dangerous Drugs Act. The prosecution’s narrative, based on police testimony, was that an informant, Eugene Tagana, acted as a poseur-buyer. Tagana allegedly handed two five-peso bills to Salcedo, who then left to retrieve the marijuana. Upon returning with the item, the police officers closed in. Salcedo allegedly threw the teabag toward a riverbank, but it was retrieved by an officer, and the marked money was recovered from his person. Forensic examination confirmed the substance was marijuana.
The defense presented a different account. Salcedo claimed Tagana merely asked him to deliver an item to someone named Magat. He asserted it was Tagana, not himself, who possessed and subsequently threw the teabag when the police arrived. The trial court favored the prosecution’s version, finding the defense incredible, and sentenced Salcedo to life imprisonment.
ISSUE
Whether the prosecution proved the guilt of the accused beyond reasonable doubt.
RULING
The Supreme Court reversed the conviction and acquitted Salcedo. The Court held that while trial court findings on witness credibility are generally respected, exceptions exist when the lower court overlooks facts of substance that would affect the case’s outcome. Here, the prosecution’s evidence was riddled with fatal inconsistencies and improbabilities. Significant contradictions existed among the police officers’ testimonies regarding the planning and execution of the buy-bust operation. Crucially, the prosecution failed to present the alleged poseur-buyer, Eugene Tagana, who was the best witness to the transaction. This failure gave rise to the presumption that his testimony would be adverse if produced.
Furthermore, the Court found the prosecution’s version improbable. The alleged sale was for a minimal amount (P10.00) and was purportedly conducted openly, within view of the police, which does not conform to common experience in drug transactions. Conviction must rest on the strength of the prosecution’s evidence, not on the weakness of the defense. The inculpatory facts were capable of an explanation consistent with innocence—that Salcedo was merely asked to deliver an item whose contents he did not know. The evidence therefore failed to meet the standard of proof beyond reasonable doubt.