G.R. No. 94644 August 17, 1993
People of the Philippines, plaintiff-appellee, vs. Michael Alejandro y Mariano, accused-appellant.

FACTS

Accused-appellant Michael Alejandro was convicted of violating Section 4, Article II of Republic Act No. 6425 (the Dangerous Drugs Act) for selling marijuana and sentenced to life imprisonment and a fine of P20,000.00 plus costs. The prosecution evidence, primarily from NARCOM operatives, established that on June 4, 1989, a buy-bust operation was conducted based on a confidential informer’s tip. Posing as a buyer, CIC Bonifacio Morados approached Alejandro at Natividad St., Tetuan, Zamboanga City. In a Chavacano conversation, Alejandro confirmed he had marijuana worth P5.00, handed over a newspaper-wrapped parcel containing dried marijuana leaves and rolling papers, and received a marked P5.00 bill in exchange. He was then arrested. The seized substance was examined by forensic chemist Athena Elisa P. Anderson and confirmed to be marijuana. Alejandro denied the charge, claiming he was arrested while buying fish and that evidence was planted on him. His witnesses, Abraham Narag and Norberto Feliciano, corroborated his arrest but not the drug sale. The defense did not present his parents as witnesses.

ISSUE

1. Whether the prosecution adequately proved the guilt of the accused for the sale of marijuana.
2. Whether the defense of frame-up or planting of evidence is credible.
3. Whether the penalty of life imprisonment for the sale of P5.00 worth of marijuana is excessive, cruel, or unjust.

RULING

The Supreme Court affirmed the conviction and dismissed the appeal. The prosecution sufficiently established that Alejandro was caught in flagrante deli cto selling marijuana. The positive identification and testimonies of the NARCOM agents prevailed over Alejandro’s denial and unsubstantiated claim of a frame-up, which the Court found inherently weak and unsupported by evidence. The Court noted the accused’s and his parents’ lack of protest during the arrest as undermining his defense. On the penalty, the Court ruled that the prescribed penalty of life imprisonment to death and a fine under the Dangerous Drugs Act, regardless of the quantity, is not cruel, inhuman, or disproportionate. The severe penalty is justified as a deterrent against the grave social scourge of drug trafficking, which is especially harmful to public interest. The law’s stern penalties are condign and necessary to combat the illicit drug trade.