GR L 70998; (October, 1986) (Digest)
G.R. No. L-70998 October 14, 1986
The People of the Philippines, plaintiff-appellee, vs. Rogelio Ale y Campesenio, defendant-appellant.
FACTS
The prosecution’s case, as presented by PC Sergeants Alejandro Biñan and Teodosio Rosaroso, was that a confidential informant reported drug pushing activity at a Knights of Columbus recreation center in Tagbilaran City. The officers supplied the informant with marked money. They testified that they observed the informant converse with appellant Rogelio Ale inside the center. Ale then left briefly, returned, and handed four marijuana sticks to the informant in exchange for the marked money. The officers immediately arrested Ale, recovering the marked bills from him and the marijuana from the informant. Forensic analysis confirmed the cigarettes were marijuana.
The defense presented a starkly different version. Ale, a billiard attendant at the center, and two defense witnesses testified that the arrest was a frame-up arising from a prior altercation. Ale claimed that in July 1984, he had asked Rosaroso to pay for a billiard game, prompting Rosaroso to threaten revenge. On the night in question, Ale was merely conversing with a friend when the officers suddenly arrested him, dragged him out, and searched him. The defense witnesses further testified that the marking of the alleged buy-bust money was done on a billiard table after the arrest, contradicting the prosecution’s claim that the bills were pre-marked.
ISSUE
Whether the prosecution proved the guilt of the appellant for the illegal sale of marijuana beyond a reasonable doubt.
RULING
No. The Supreme Court reversed the conviction and acquitted appellant Rogelio Ale on the ground of reasonable doubt. The Court emphasized that when inculpatory facts are susceptible to two interpretations—one consistent with guilt and another with innocence—the evidence fails the test of moral certainty required for conviction.
The legal logic centered on the irreconcilable contradictions between the prosecution and defense narratives, which created doubt on the very occurrence of the buy-bust operation. The defense’s claim of a motive for revenge by prosecution witness Rosaroso, while uncorroborated, was notably uncontradicted by the prosecution. Furthermore, the defense witnesses directly challenged the prosecution’s timeline and procedure by testifying that the money was marked post-arrest, not before. The non-presentation of the confidential informant, while not always fatal, became significant here as it left the core transaction uncorroborated by a direct participant, especially when the arresting officers’ testimonies were contested by other witnesses. The Court found the evidence did not overcome the constitutional presumption of innocence, as the defense’s version was plausible and consistent with the evidence of a grudge. Consequently, the doubt was resolved in favor of the accused.
