G.R. No. 99838 October 23, 1997
People of the Philippines vs. Ernesto Enriquez y Rosales and Wilfredo Rosales y Yucot

FACTS

Accused-appellants Ernesto Enriquez and Wilfredo Rosales were charged with the illegal sale of marijuana. The prosecution evidence established that on June 5, 1990, following a tip from a civilian informant, a buy-bust operation was conducted at North Harbor, Manila. Police officers, with Patrolwoman Shirley Maramot acting as the poseur-buyer, met with Rosales, who led them to Enriquez’s house. Enriquez asked for the money, and upon being shown the marked bills, allowed the group inside. Rosales later emerged carrying a plastic sack containing six kilograms of marijuana. Upon the pre-arranged signal, the backup team arrested Rosales. Enriquez initially fled but was later apprehended. The marked money was subsequently recovered from Enriquez’s wife.
The defense presented a different version, claiming the incident was a frame-up. Enriquez testified that he was merely at the pier looking for work when he was forcibly taken by police officers to a detachment. He alleged he was mauled and forced to admit ownership of the marijuana, and that the marked money was planted on his wife. Rosales claimed he was merely acting as a porter and was instructed by a man to carry the bag, unaware of its contents, when he was arrested.

ISSUE

The core issue is whether the prosecution successfully proved the guilt of the accused beyond reasonable doubt for the illegal sale of a prohibited drug.

RULING

The Supreme Court affirmed the conviction. The Court upheld the trial court’s assessment of the credibility of the witnesses, giving great weight to the straightforward testimonies of the police officers who conducted the legitimate buy-bust operation. The defense of frame-up and denial were found weak and self-serving, especially in light of the clear and corroborated details of the sale, including the recovery of the marked money from the appellant’s own wife. The Court ruled that all elements of the crime were present: (1) the identity of the buyer and seller, the object, and the consideration; and (2) the delivery of the thing sold and the payment. The presentation of the confiscated marijuana as an exhibit, coupled with the positive forensic report confirming it was marijuana, constituted sufficient proof of the corpus delicti. The defense failed to provide clear and convincing evidence to overcome the presumption of regularity in the performance of official duty by the apprehending officers. The penalty of life imprisonment and a fine of P30,000.00 was thus affirmed.