GR 97086; (May, 1992) (Digest)
G.R. No. 97086 May 8, 1992
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDGARDO CANELA Y ARANETA, accused-appellant.
FACTS
Accused-appellant Edgardo Canela was charged with violating Article II, Section 5 of Republic Act No. 6425 , as amended (Dangerous Drugs Act), for allegedly selling and delivering approximately 5 grams of dried marijuana fruiting tops to a poseur-buyer, Sgt. Dominador Cruz, for P20.00 on May 17, 1988, in Lucena City. The prosecution’s version, based on a “buy-bust” operation, was that a NARCOM team, acting on information, conducted the operation where Sgt. Cruz, as poseur-buyer, purchased marijuana from the accused-appellant using marked money, after which the accused-appellant was arrested and the marked money and other items were recovered from him. The accused-appellant pleaded not guilty and was convicted by the Regional Trial Court and sentenced to reclusion perpetua and a fine. The accused-appellant’s version was that he was an innocent bystander at a billiard hall where an actual drug transaction between a civilian informer and another person occurred; when that person fled, he dropped the marijuana and money near the accused-appellant, who was then falsely arrested, interrogated, and slapped by the NARCOM agents when he could not identify the fugitives or pay a demanded sum of P12,000 for his release.
ISSUE
Whether the prosecution proved the guilt of the accused-appellant for the illegal sale of marijuana beyond a reasonable doubt.
RULING
The Supreme Court REVERSED the decision of the trial court and ACQUITTED the accused-appellant on the ground of reasonable doubt. The Court found the prosecution’s evidence weak due to conflicting and inconsistent testimonies of its witnesses on material points, which engendered doubt as to the guilt of the accused-appellant. The inconsistencies noted by the Court pertained to: the formation of the buy-bust team (whether by mission order or mere information); the composition of the team; the presence of a civilian informer with the team; the source and marking of the money used; the time of the operation; the conduct of the exchange (whether the accused-appellant left to get the marijuana or not); and the articles allegedly seized from the accused-appellant. The Court also noted the failure of the arresting officers to follow established procedure. The Court held that the accused-appellant was made the “fall-guy” for an unsuccessful buy-bust operation and emphasized the need for vigilance against trumped-up drug charges.