GR 92270; (June, 1991) (Digest)
G.R. No. 92270 ; June 27, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALBERTO GARCIA y RODRIGUEZ, accused-appellant.
FACTS
Accused-appellant Alberto Garcia was charged with violating the Dangerous Drugs Act for allegedly selling two tea bags of marijuana during a buy-bust operation in Camiling Public Market, Tarlac, on October 27, 1988. The prosecution presented police officers who testified that a team, acting on a tip, conducted the operation where Sergeant Ballesteros acted as poseur-buyer. Ballesteros paid marked money to Garcia in exchange for the marijuana, witnessed by other team members. Garcia was arrested, and two marked five-peso bills were recovered from him. Forensic tests confirmed the substance was marijuana.
Garcia presented a different version, claiming he was merely selling native cakes when soldiers searched him without a warrant, took two five-peso bills from his pocket, and brought him to the police station where he was made to sign a receipt without counsel. The trial court found the prosecution’s version credible, convicted Garcia, and sentenced him to reclusion perpetua and a fine.
ISSUE
The core issue is whether the trial court erred in convicting Garcia based on the credibility of the prosecution witnesses and the evidence presented, despite his defenses of denial and alleged irregularities in the arrest and seizure.
RULING
The Supreme Court affirmed the conviction. The Court emphasized that trial court findings on witness credibility are generally binding unless substantial facts were overlooked. The prosecution established Garcia was caught in flagrante delicto through a valid buy-bust operation. The testimonies of the poseur-buyer and corroborating officers were consistent and credible, proving the sale and recovery of marked money. The defense of denial could not prevail over this positive identification.
The Court rejected Garcia’s arguments. First, the claim that the marijuana examined was not taken from him was untenable given the clear chain of custody and testimonial evidence. Second, the public nature of the transaction at a market did not make it unbelievable, as drug pushes can occur swiftly in public places, often using such settings as camouflage, as upheld in prior cases like People v. Paco. Third, the warrantless arrest and search were valid as incidental to a lawful arrest after Garcia was caught in the act. The Court stressed the grave societal harm of drug trafficking and upheld the penalty imposed.