GR 96319; (March, 1992) (Digest)
G.R. No. 96319 . March 31, 1992.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RENATO ARCEGA, accused-appellant.
FACTS
Accused-appellant Renato Arcega was convicted for violating the Dangerous Drugs Act. The prosecution evidence established that a police team conducted a buy-bust operation in Malabon. A confidential informant arranged a transaction, and Pat. Benjamin Sales acted as the poseur-buyer. Sales met Arcega, requested twenty sticks of marijuana, paid P50.00 with marked money, and gave a pre-arranged signal upon receipt. The team arrested Arcega, recovering the marked money. Arcega then voluntarily surrendered an additional 140 sticks of marijuana. Forensic tests confirmed all items were marijuana.
Arcega denied the sale, claiming he was forcibly taken from his home by men looking for his brother, brought to a police station, and forced to sign marijuana sticks. He presented no other witnesses.
ISSUE
Whether the trial court erred in convicting the accused based on the credibility of the prosecution witnesses and the sufficiency of the evidence.
RULING
The Supreme Court affirmed the conviction. The core issue involved witness credibility, where appellate courts generally defer to the trial court’s assessment. The positive, categorical, and consistent testimonies of the police officers, who are presumed to have regularly performed their duties, prevailed over Arcega’s bare denial. The alleged minor inconsistencies in the police testimony regarding the timeline and address were deemed inconsequential and did not undermine the essential narrative of the buy-bust sale and the subsequent recovery of drugs.
The Court found the elements of illegal sale and possession duly proven: the transaction occurred, the marijuana was presented as evidence, and payment was made. Arcega’s voluntary surrender of the additional 140 sticks further corroborated his involvement. The defense failed to provide clear and convincing evidence of any ill motive on the part of the police to fabricate the charges. The penalty of life imprisonment and a P20,000.00 fine under the amended law was correctly imposed. The judgment of the trial court was affirmed in toto.