G.R. No. 92150 December 8, 1993
People of the Philippines, plaintiff-appellee, vs. Efren Malakas, accused-appellant.

FACTS

On April 21, 1989, a NARCOM team conducted a buy-bust operation in San Pablo City based on a civilian informer’s report that Efren Malakas was selling drugs. Sgt. Elpidio Anasta acted as the poseur-buyer. According to the prosecution, Anasta approached Malakas, who was watching a basketball game, and said, “Pare, mayroon ba tayo diyan, may kumpromiso ako sa aking barkada?” Without a word, Malakas left, returned after two minutes, and handed Anasta a plastic bag containing forty sticks of marijuana cigarettes. Anasta then gave a marked P50-bill and raised his left hand as a signal. After about two minutes, other agents moved in to arrest Malakas. The seized items were confirmed to be marijuana by the crime laboratory.
The accused, Efren Malakas, presented a different version. He claimed he was at the location for a basketball game. He saw a known drug pusher, Virgilio “JR” Villamin, conversing with two unknown persons (later identified as NARCOM agents). After money was handed to Villamin, someone shouted “PC! PC!” causing a commotion. While fleeing, Malakas was caught by the agents. He pleaded with them, saying he was not a pusher, but he was beaten, blindfolded, and taken to Lucena City. He alleged that while detained, Pfc. Maderazo told him, “Pasensiya ka na, at ikaw ang nahuli. The PC will not go home without any apprehension.”
The trial court found Malakas guilty of violating the Dangerous Drugs Act and sentenced him to reclusion perpetua and a fine.

ISSUE

Whether the prosecution proved the guilt of the accused beyond reasonable doubt based on the evidence presented regarding the buy-bust operation.

RULING

The Supreme Court REVERSED and SET ASIDE the trial court’s decision and ACQUITTED accused Efren Malakas. The prosecution failed to prove his guilt beyond reasonable doubt.
The Court found the prosecution’s version of the buy-bust operation highly improbable and inconsistent. Key points of doubt included:
1. Lack of Negotiation: The poseur-buyer’s statement did not inform the accused of the quantity or price of drugs being purchased. The Court held it was unlikely a drug peddler would simply leave and return with a specific quantity without any prior discussion on the amount needed or the payment.
2. Incredible Testimonies: Sgt. Anasta, the poseur-buyer, could not recall how much he paid for the marijuana. Pfc. Maderazo gave conflicting testimonies, first stating he did not see the actual exchange, then later claiming he saw the accused hand over the drugs first before payment was made.
3. Unnatural Delay: The arresting officers took two whole minutes to respond to the pre-arranged signal despite being only about ten meters away, which is contrary to the swift action expected in genuine buy-bust operations.
4. Credibility of Defense: The Court found the accused’s claim—that he was framed because the officers did not want to return empty-handed—to be plausible under the circumstances, noting that the defense evidence was not inherently unbelievable.
The Court emphasized that in drug cases, the evidence for the prosecution must stand on its own merit and cannot draw strength from the weakness of the defense. The inconsistencies and improbabilities in the prosecution’s narrative created reasonable doubt. Furthermore, the Court noted the trial judge’s error in equating “reclusion perpetua” with “life imprisonment,” citing Administrative Circular No. 6-92 which clarifies the distinction.