G.R. No. L-68951 June 16, 1988
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. FRANCIS DE GUZMAN y GALANG, accused, MANUEL DURIAS y ASTRERO, ROBERT LIZARDO y KANGA, alias ROBERT RIZALDO, ISABELO TALLEDO y ESPIRITU, and ARSENIO SABAWIL y POLON, accused-appellants.

FACTS

Accused-appellants Manuel Durias, Isabelo Talledo, Robert Lizardo, and Arsenio Sabawil, together with Francis de Guzman, traveled together from Santiago, Isabela to Quezon City. On January 5, 1984, NARCOM agents arrested all five in a buy-bust operation. The prosecution evidence established that De Guzman and Durias negotiated the sale of three kilos of marijuana to an undercover agent, CIC Cesar Dalonos. Upon agreement on the price, Durias signaled the others. Talledo then drove off with Lizardo and Sabawil and returned half an hour later, with Lizardo and Sabawil handing over the marijuana to Dalonos, leading to their arrest. All were convicted for violating the Dangerous Drugs Act, with the four appellants sentenced to life imprisonment.
Durias and Talledo, the jeep owner and driver, denied conspiracy, claiming they were merely hired to transport Lizardo and Sabawil to Quezon City for a fare and were unaware of the marijuana. They asserted they were waiting for payment when suddenly arrested. Lizardo separately argued the prosecution failed to prove the marijuana’s chain of custody and his lack of license to possess it. Their defenses were inconsistent; Durias and Talledo distanced themselves from the others, while Lizardo and Sabawil presented a different account.

ISSUE

Whether the guilt of the accused-appellants for the sale of marijuana was proven beyond reasonable doubt, particularly regarding the existence of a conspiracy.

RULING

The Supreme Court affirmed the conviction, holding that the prosecution proved the appellants’ guilt beyond reasonable doubt. The Court found the collective actions of the five men demonstrated a conspiracy to sell marijuana. The negotiation by De Guzman and Durias, the pre-arranged signal by Durias, the retrieval trip made by Talledo, Lizardo, and Sabawil, and the final delivery by Lizardo and Sabawil constituted an indivisible, coordinated criminal operation. The act of one was thus the act of all.
The Court rejected the separate defenses as unconvincing and riddled with inconsistencies. It highlighted that Durias’s own “Prayer for Acquittal” contradicted his trial testimony by admitting his jeep was hired to transport vegetables, supporting the prosecution’s narrative that the marijuana was concealed within a vegetable shipment. The exorbitant fare charged to Lizardo and Sabawil, the special trip to West Avenue beyond the normal terminal, and the provision of free meals and rest at Talledo’s sister’s house were circumstances incompatible with a mere carrier-passenger relationship and instead indicated prior association and common criminal purpose. The minor inconsistencies in prosecution testimony did not undermine the core narrative of the buy-bust operation. All appellants were found guilty as conspirators and, alternatively, as principals by direct participation in the transport, possession, and sale of prohibited drugs.