G.R. No. 98398 July 6, 1993
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. RAUL ROLDAN y SAMSON, LAURO SANTIAGO y CRUZ and LITO DE LA CRUZ y SEBASTIAN, accused-appellants.

FACTS

Accused Raul Roldan y Samson, Lauro Santiago y Cruz, and Joselito de la Cruz y Sebastian were charged with violating Section 4, Article II of R.A. No. 6425 (Dangerous Drugs Act) for selling twenty tea bags of marijuana to Pat. Nemesio L. Ira in a buy-bust operation on October 22, 1990, in Navotas, Metro Manila. Upon arraignment, all pleaded not guilty. The charge against Joselito de la Cruz was later dismissed. After trial, the court convicted Roldan and Santiago, sentencing each to life imprisonment and a P20,000 fine.
The prosecution’s version, based on the testimonies of Pat. Nemesio Ira and Cpl. Roland Mabbun, is that police received complaints about marijuana sales near a basketball court. A civilian informer successfully bought marijuana from suspects “Raul” and “Larry.” A buy-bust team was formed with Pat. Ira as the poseur-buyer. The informer introduced Ira to Roldan and Santiago. Ira bought P30 worth of marijuana, giving marked money. Roldan and Santiago retrieved tea bags from under a wood pile, joined by de la Cruz, and handed them to Ira. Upon Ira’s signal, the team arrested them. Roldan led them to a nestogen can under the wood pile containing 17 more tea bags. The marked money was recovered. Forensic examination confirmed the substances were marijuana.
The defense claimed they were merely sitting near the basketball court when policemen arrested them without a buy-bust operation. They alleged Cpl. Mabbun tried to force them to admit ownership and implicate a certain Jojo Florendo. A witness, Anna Rose Rafael, corroborated their claim of being arrested without a buy-bust.

ISSUE

Whether the trial court erred in giving credence to the prosecution witnesses’ testimony over the defense’s version, thereby convicting the accused.

RULING

The Supreme Court affirmed the trial court’s decision, finding no error in its credibility assessment. The Court reiterated the principle that trial courts’ factual findings, especially on witness credibility, are accorded great respect, as the trial judge observes the witnesses’ demeanor firsthand. Appellate courts will not disturb these findings unless the trial court overlooked substantial facts or arbitrarily disregarded significant circumstances. The appellants failed to show any such reason to depart from this rule.
The Court addressed the appellants’ specific contentions: 1) The alleged ill motive of Cpl. Mabbun (forcing an implication of Jojo Florendo) was not proven and did not discredit the consistent prosecution narrative. 2) Minor inconsistencies in the prosecution’s testimony (e.g., the exact number of initial test buys) were deemed trivial and did not affect the core facts of the buy-bust. 3) The defense’s denial and frame-up claim were weak and unsupported by clear evidence, whereas the prosecution presented a straightforward and credible account of the entrapment. The positive identification by the poseur-buyer and the recovery of marked money and drugs prevailed over the bare denials. Therefore, the conviction was upheld.