G.R. No. L-70569, January 7, 1987
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MICHAEL MADARANG y SANTOS, accused-appellant.

FACTS

Accused-appellant Michael Madarang was convicted by the Regional Trial Court for violating the Dangerous Drugs Act ( R.A. No. 6425 , as amended) and sentenced to life imprisonment and a fine. The prosecution evidence established that on July 12, 1982, in Burgos, La Union, a police team, acting on a tip, conducted an entrapment operation. Sergeant Roberto Viloria posed as a buyer. Madarang, together with his co-accused Cirilo Juan (who remained at large), approached the police jeepney. Madarang directly negotiated with Viloria, stating the price of the marijuana at P600 per kilo, showed a sample, and insisted on this price during bargaining. Upon Viloria’s signal, the team arrested Madarang and Juan and confiscated the plastic bag containing approximately 800 grams of marijuana, which was later chemically confirmed.
The defense presented a different version. Madarang, then 18 years old, claimed he was merely asked by his friend Juan to accompany him to meet some people. He testified he was unaware of the bag’s contents until they were inside the jeepney, where he merely observed the transaction without participating. He asserted he was shocked upon the arrest and did not protest because he was innocent, later signing a waiver for his detention without fully understanding the implications.

ISSUE

Whether the accused-appellant Michael Madarang is guilty beyond reasonable doubt of the illegal sale of marijuana under Section 4 of R.A. No. 6425 , as amended.

RULING

The Supreme Court affirmed the conviction. The Court found the prosecution’s version credible and supported by the clear, consistent, and straightforward testimonies of the police officers involved in the entrapment. The defense of denial and frame-up was rejected. The Court emphasized that in buy-bust operations, the testimony of the poseur-buyer enjoys a presumption of regularity in the performance of official duties, which Madarang failed to rebut with clear and convincing evidence.
The legal logic centers on the elements of the crime and Madarang’s direct participation. For illegal sale of prohibited drugs, the prosecution must prove: (1) the identity of the buyer and seller, the object, and the consideration; and (2) the delivery of the thing sold and the payment. All these were established through Viloria’s testimony detailing the negotiation where Madarang actively quoted the price, showed a sample, and bargained. The Court ruled that ownership or possession of the drug is not an indispensable element of the crime under Section 4. The mere act of selling, or acting as a broker in the sale, consummates the offense. By negotiating the sale to Viloria, Madarang took a direct and active part in the transaction, regardless of whether the marijuana belonged primarily to Juan. His post-arrest conduct, including his failure to vigorously protest his innocence and his meek signing of a detention waiver, further undermined his defense. Consequently, his guilt was proven beyond reasonable doubt.