G.R. No. 94369 October 28, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALFREDO CO y UMALI, accused-appellant.

FACTS

Accused-appellant Alfredo Co y Umali was convicted by the Regional Trial Court of Pasig for violating Section 4 of Republic Act No. 6425 (Sale of Prohibited Drugs) and sentenced to reclusion perpetua and a fine. The prosecution evidence established that on July 26, 1986, a buy-bust operation was conducted in Pasig, Metro Manila. Patrolman Ramon Peraja acted as the poseur-buyer. Appellant approached Peraja and, after a brief conversation where Peraja agreed to buy P20 worth of marijuana, appellant received the marked money and handed over dried marijuana fruiting tops wrapped in notebook paper. Peraja immediately arrested the appellant, and the seized item was forwarded to the PC Crime Laboratory, where it was confirmed to be marijuana.
The defense presented a different version. Appellant and his aunt, Maxima Concepcion, testified that he was arrested without cause while helping at a relative’s food store. He claimed he was not frisked, was brought to the police station, and was forced to sign a prepared statement without reading it. The trial court, however, found the prosecution’s narrative credible and convicted the appellant.

ISSUE

The core issue is whether the trial court erred in convicting the accused-appellant based on the credibility of the prosecution witnesses and the integrity of the evidence presented.

RULING

The Supreme Court affirmed the conviction. The Court emphasized the well-settled doctrine that factual findings of the trial court, particularly on witness credibility, are accorded high respect and finality unless there is a clear showing that it overlooked or misapplied significant facts. The trial court was in the best position to observe the witnesses’ demeanor and found the prosecution’s evidence, primarily Patrolman Peraja’s straightforward testimony on the buy-bust sale, to be credible and convincing.
Appellant’s arguments were found unmeritorious. The prosecution’s discretion to present only essential witnesses like Peraja, whose testimony was direct and sufficient, is beyond reproach; the non-presentation of other team members does not imply adverse testimony. The Court also upheld the integrity of the evidence chain, noting the seized item was confiscated during the buy-bust, promptly submitted for laboratory examination, and positively identified as marijuana. In contrast, the defense testimonies were riddled with material inconsistencies regarding the appellant’s relationship with his witness, his daily activities, and the circumstances of his arrest, as meticulously detailed by the trial court. Therefore, the guilt of the appellant was proven beyond a reasonable doubt.