G.R. No. 97960 May 10, 1994
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. EDUARDO CAMBA Y RAPISORA, accused-appellant.

FACTS

Accused-appellant Eduardo Camba, a fisherman, was charged with violating Section 4, Article II of R.A. No. 6425 (Dangerous Drugs Act of 1972), as amended. The information alleged that on January 30, 1989, in Navotas, Metro Manila, he willfully sold two tea bags of marijuana fruiting tops and was found in possession of an additional four tea bags, with a total weight of 14.2 grams. The prosecution’s evidence, based on a tip from a confidential informant, was that a police team was dispatched, with Pat. Rizalito Francisco acting as a poseur-buyer. Francisco allegedly bought two tea bags from Camba using a marked twenty-peso bill. Upon a pre-arranged signal, backup officers arrested Camba and allegedly seized a total of six tea bags. The seized items were examined by a forensic chemist, who confirmed they were marijuana. The defense presented a different version: Camba was waiting for his wages when four policemen, two of whom were his former neighbors, arrested him without cause. He alleged that the policemen took P350.00 from his wallet and his wristwatch, and later demanded P6,000.00 from his wife to drop the case. The trial court convicted Camba, sentencing him to reclusion perpetua and a fine.

ISSUE

Whether the prosecution’s evidence was sufficient to prove the guilt of the accused-appellant beyond reasonable doubt for the illegal sale and possession of marijuana.

RULING

The Supreme Court REVERSED the trial court’s decision and ACQUITTED accused-appellant Eduardo Camba on the ground of reasonable doubt. The Court found the prosecution’s evidence insufficient and haphazard, failing to meet the required quantum of proof. Key deficiencies included: (1) The poseur-buyer, Pat. Rizalito Francisco, admitted on cross-examination that he did not actually know if the accused was selling marijuana at the time of arrest. (2) None of the arresting officers identified the alleged six tea bags of marijuana in court as evidence; no tea bag was formally offered and marked as an exhibit. Only the forensic chemist’s Certification of Laboratory Result was presented, but the specimen itself was not shown to be the same one seized from the accused. (3) There were inconsistencies in the testimonies regarding the composition of the police team. (4) The defense’s claim of extortion by the policemen was not rebutted by the prosecution. The Court emphasized that the presumption of innocence must prevail, and guilt must be established by proof beyond reasonable doubt, which was not achieved due to the prosecution’s failure to present crucial evidence and clarify material gaps and contradictions.