G.R. No. 94994 -95 May 14, 1993
People of the Philippines, plaintiff-appellee, vs. Lilibeth Caco y Palmario and Teodoro Caco y Lapada, accused. Lilibeth Caco y Palmario, accused-appellant.

FACTS

Accused spouses Teodoro and Lilibeth Caco were charged with violating Section 4, Article II of the Dangerous Drugs Act of 1972 ( R.A. No. 6425 ), as amended, for selling ten (10) sticks of marijuana cigarettes. The case was docketed as Criminal Case No. 10108-V-90. A separate case (Criminal Case No. 10106-V-90) against other individuals for smoking marijuana in the Cacos’ house was consolidated with it. After trial, the Regional Trial Court of Valenzuela acquitted all accused in the second case and Teodoro Caco in the first case, but convicted Lilibeth Caco of illegal sale of marijuana. She was sentenced to life imprisonment and a fine.
The prosecution evidence established that on February 23, 1990, a buy-bust operation was conducted based on information that the spouses were selling marijuana. Patrolman Wilfredo Quillan acted as poseur-buyer and, with Patrolman Rafael Tamayo, went to the accused’s house. Lilibeth Caco received a marked P20.00 bill, went inside the house, and returned to hand over ten sticks of marijuana. Upon her arrest, police found two rouches of marijuana on the floor inside the house, and Teodoro Caco surrendered eighty-nine (89) more sticks. All seized items were confirmed to be marijuana. The defense presented witnesses claiming the door was open and contesting the police narrative.

ISSUE

The core issue is whether the prosecution proved the guilt of accused-appellant Lilibeth Caco for the illegal sale of marijuana beyond reasonable doubt.

RULING

The Supreme Court AFFIRMED the trial court’s decision convicting Lilibeth Caco. The Court held that the buy-bust operation was legitimate and established the illegal sale. The minor inconsistencies in the testimonies of the police officers (Quillan and Tamayo) regarding peripheral details (e.g., when they introduced themselves, whether women inside were sitting or dancing) did not undermine their credibility on the essential fact of the sale. The search and seizure of the additional marijuana sticks were deemed lawful as an incident to a lawful arrest, pursuant to Section 12, Rule 126 of the Rules of Court. The Court found the evidence against Lilibeth Caco—her receipt of the marked money and delivery of the marijuana—to be overwhelming and sufficient for conviction beyond reasonable doubt. The penalty of life imprisonment was upheld as proper for drug pushing.