G.R. No. 97427 May 24, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO CRISOSTOMO y PAREDES alias “BONICOL”, accused-appellant.

FACTS

Accused-appellant Reynaldo Crisostomo y Paredes alias “Bonicol” was charged with violation of Section 4 of Republic Act No. 6425 (Dangerous Drugs Act of 1972) for the alleged sale and distribution of approximately 135 grams of dried marijuana leaves in Iloilo City on or about March 4, 1987. The prosecution’s case, as summarized by the trial court, stemmed from a buy-bust operation. Information from an arrested individual, Lennie Placida, led Narcom agents to “Bonicol” in Brgy. MacArthur, La Paz, Iloilo City. C1C Freddie Cartel acted as the poseur-buyer and was given six marked P100.00 bills. At the location, Cartel asked a seated person about “Bonicol,” who then identified himself and asked if Cartel wanted to “score.” Cartel handed over P600.00, and the person returned with marijuana wrapped in newspaper. Upon verification, a pre-arranged signal was given, and the accused was arrested. The marked money was later recovered from his wallet, and forensic tests confirmed the substance was marijuana. The trial court convicted the accused and sentenced him to life imprisonment and a fine. On appeal, the accused argued errors in the conviction, the lack of counsel during his arrest and signing of the receipt of seized articles, and that he was a “fall guy.”

ISSUE

Whether the prosecution proved the guilt of the accused for the illegal sale of marijuana beyond reasonable doubt.

RULING

The Supreme Court REVERSED the trial court’s decision and ACQUITTED accused-appellant Reynaldo Crisostomo on the ground of reasonable doubt. The Court found material inconsistencies in the testimonies of the prosecution witnesses, Sgt. Benito Bonete and C1C Freddie Cartel, which created reasonable doubt. Specifically, there were discrepancies regarding the composition of the buy-bust team (whether Sgt. Allaga was present) and, more critically, regarding the initial contact between the poseur-buyer and the alleged pusher. Sgt. Bonete testified that the alleged pusher approached Cartel, while Cartel testified that he approached a seated person and asked for “Bonicol.” This conflict in the commencement of the sales transaction was irreconcilable and material. The Court held that when inculpatory facts are capable of two or more explanations, one of which is consistent with innocence, the required moral certainty for conviction is not met. The prosecution failed to overcome the constitutional presumption of innocence with clear, credible, and convincing evidence. Given this disposition, the Court deemed it unnecessary to discuss in detail the alleged violation of the accused’s right to counsel.