G.R. No. 93852 . January 24, 1992.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DANDY DE JESUS, accused-appellant.

FACTS

Accused-appellant Dandy de Jesus was convicted by the Regional Trial Court for selling three tea bags of dried marijuana leaves in violation of the Dangerous Drugs Act. The prosecution evidence, presented through police officers Pfc. Efren Arevalo and Pat. Nemesio Ira, established that a buy-bust operation was conducted on September 26, 1989, in Navotas. Arevalo acted as a poseur-buyer and, after being approached, appellant handed over the marijuana in exchange for marked money. Ira, positioned nearby, witnessed the transaction and effected the arrest. The seized items were confirmed by the NBI to be marijuana.
The defense presented an entirely different version. Appellant claimed he was forcibly taken by policemen while bathing at a neighbor’s house, brought to the station, and coerced through physical abuse to admit to the crime. He alleged the charge was fabricated. To support this, the defense presented statements filed with the National Police Commission months after the incident, but the trial court noted the delay and lack of proof of actual filing.

ISSUE

The core issue is the credibility of the witnesses, determining whether the prosecution proved the illegal sale beyond reasonable doubt or whether the defense’s claim of frame-up should prevail.

RULING

The Supreme Court affirmed the conviction. The ruling hinges on the well-settled doctrine that the trial court’s findings on witness credibility are entitled to great weight and respect, as it had the direct opportunity to observe demeanor. The Court found no compelling reason to deviate from this rule, as no facts were overlooked that would alter the case outcome. The prosecution witnesses, being police officers, are presumed to have performed their duties regularly in the absence of clear evidence to the contrary.
The defense’s claim that it was improbable for appellant to sell to a known policeman was deemed unpersuasive and uncorroborated. The Court also noted the unlikelihood that the officers would falsely charge a relative of their fellow policeman. Appellant’s defense of frame-up and alibi could not prevail over the positive, categorical identification by the prosecution witnesses. The elements of the crime—the sale, delivery, and the illicit nature of the drug—were sufficiently established by the prosecution’s evidence. Thus, the judgment of the trial court imposing life imprisonment and a fine was upheld.