G.R. No. 88282 May 6, 1992
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDWIN PASCUAL y FLORES, accused-appellant.

FACTS

Accused Edwin Pascual was charged with violating Section 4, Article II of Republic Act No. 6425 (Dangerous Drugs Act) for allegedly selling, delivering, and giving away 3.80 grams of marijuana fruiting tops on May 28, 1988, in Pateros, Metro Manila. After pleading not guilty, trial ensued. The prosecution’s evidence, based on police testimony, established that a buy-bust operation was conducted after surveillance identified a pusher known as “Tabo.” Pat. Armando de Villa acted as poseur-buyer and used three xeroxed ten-peso bills to purchase three tea bags of marijuana from the accused. Upon the pre-arranged signal, backup officers arrested the accused, recovering the marked bills from him. Forensic analysis confirmed the substance was marijuana. The defense, comprising the accused and three witnesses, denied the sale, claiming the accused was merely resting near his house when arrested without warrant, handcuffed, frisked (finding only a plastic bag of rice), and brought to the police station where he was forced to admit the offense. The trial court found the accused guilty beyond reasonable doubt and sentenced him to reclusion perpetua, a fine, and costs.

ISSUE

1. Whether the trial court erred in finding the testimony of the police officers more credible than that of the defense witnesses.
2. Whether the evidence for the prosecution constitutes proof beyond reasonable doubt.
3. Whether the constitutional rights of the accused against warrantless arrest and unreasonable search were violated.

RULING

The Supreme Court affirmed the conviction but modified the penalty.
1. The trial court’s assessment of witness credibility is generally not disturbed on appeal, as it is in a better position to observe witness demeanor. The positive testimonies of the police officers prevail over the negative testimony of the accused. No improper motive was imputed to the officers, who are presumed to have performed their duty regularly.
2. The prosecution evidence, including the credible buy-bust operation and forensic confirmation, established guilt beyond reasonable doubt. The defense’s arguments were deemed mere conclusions insufficient to overturn the conviction.
3. The warrantless arrest and search were lawful. The accused was caught in flagrante delicto selling marijuana, justifying arrest under Section 5(a), Rule 113 of the Rules of Court. The search incidental to a lawful arrest, which yielded the marked bills, was valid under Section 12, Rule 126.
The penalty was modified: Section 4 of Republic Act No. 6425, as amended, prescribes life imprisonment to death and a fine, not reclusion perpetua (which carries accessory penalties under the Revised Penal Code and is distinct from life imprisonment). Thus, the penalty was changed from reclusion perpetua to life imprisonment. The decision was affirmed with this modification.