GR 90853; (March, 1991) (Digest)
G.R. No. 90853; March 13, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENATO ZAPANTA y CENTENO @ BEBOT, accused-appellant.
FACTS
The accused, Renato Zapanta, was convicted by the Regional Trial Court of Cavite for violating the Dangerous Drugs Act (drug-pushing) and sentenced to reclusion perpetua. The prosecution alleged that on July 7, 1987, he sold three sticks of marijuana to a poseur-buyer during a buy-bust operation. Police testimony stated that an informer and a runner, Romeo Boter, used marked money to purchase marijuana from Zapanta in his shanty. Upon the transaction, policemen arrested Zapanta and claimed to have found marijuana during a warrantless search of his premises.
Zapanta pleaded not guilty and presented a different account. He testified that he was bed-ridden due to a severe kidney infection and was resting when policemen forcibly searched his home without a warrant. He denied selling marijuana, asserting that money found on him was for medicine. His sister corroborated his testimony, and he presented a barangay certification of good character, though the barangay captain was not called to testify.
ISSUE
Whether the prosecution proved beyond reasonable doubt that Zapanta was guilty of selling marijuana.
RULING
No, the prosecution failed to prove guilt beyond reasonable doubt. The Supreme Court reversed the conviction and acquitted Zapanta. The legal logic centered on the unreliability of the prosecution’s evidence due to material inconsistencies and constitutional violations. Witness testimonies were irreconcilable on key points: the presence of the informer during the raid, the number of marijuana sticks involved (with claims varying from one to five), and whether the informer was known to the police. These inconsistencies eroded the witnesses’ credibility.
Critically, the warrantless search and seizure of the alleged marijuana was illegal, rendering the evidence inadmissible. The marijuana was not found on Zapanta’s person but allegedly from the runner, Boter, and the marked money was not recovered from the accused. Given Zapanta’s attested physical disability and poverty, the Court found the scenario of him engaging in drug trafficking improbable. The constitutional presumption of innocence must prevail when the evidence is weak and tainted. While commending anti-drug efforts, the Court emphasized vigilance against fabricated charges, as the severe penalties for drug offenses demand the highest standard of proof, which was not met here.