G.R. No. L-62467. October 31, 1983.
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REYNALDO BROQUEZA Y STA. ANA, defendant-appellant.

FACTS

The prosecution’s evidence established that on November 25, 1981, a Constabulary Anti-Narcotics Unit (CANU) team, acting on a tip, conducted an entrapment operation on Milagros Street, Sta. Cruz, Manila. Policewoman Lolita Opeñano, accompanied by a confidential informant, was approached by appellant Reynaldo Broqueza, who offered to sell marijuana. Opeñano agreed, gave a marked P10.00 bill, and appellant left, returning minutes later to deliver five sticks of marijuana cigarettes. Upon delivery, the team arrested him. The cigarettes were later confirmed by laboratory examination to be marijuana. Appellant, in his defense, claimed he was merely gathering scrap iron when an unidentified man asked him to deliver P10.00 to a certain “Connie.” He alleged he complied, received a wrapped item from Connie, delivered it to the man, and was then arrested. The trial court convicted him of violating the Dangerous Drugs Act, sentencing him to life imprisonment and a fine.

ISSUE

Whether the prosecution proved the guilt of the accused beyond reasonable doubt.

RULING

The Supreme Court reversed the conviction and acquitted the appellant. The legal logic centered on the insufficiency of the prosecution’s evidence to meet the required standard of proof beyond reasonable doubt. The Court found the circumstances surrounding the arrest and the evidence presented inconsistent with moral certainty of guilt. Crucially, the Court ruled the extrajudicial confession (Exhibit “D”) inadmissible. The document showed the arresting officers read the appellant his constitutional rights, but his response to the three comprehensive questions regarding his right to remain silent and to counsel was a single, brief statement in the affirmative. Applying the standard from People vs. Caguioa, the Court held this did not constitute a voluntary, knowing, and intelligent waiver of his right to counsel. The waiver was invalid as the appellant’s short, generalized reply failed to demonstrate a full understanding of the rights being relinquished. With the confession excluded, the remaining evidence was deemed inadequate to overcome the presumption of innocence. The prosecution’s narrative, when weighed against the appellant’s defense, failed to eliminate reasonable doubt. The Court thus ordered his acquittal but directed the forfeiture of the marijuana cigarettes.