People v. Abedes
REITERATIONFacts
The Antecedents: Ramon Abedes y Salgado was accused of violation of Section 4, Article II of RA 6425, as amended by PD 1675 (Dangerous Drugs Act). An informer tipped off the Anti-Narcotics Command about appellant's illicit drug dealings. An entrapment operation was conducted where Sgt. Angelito Manalo posed as a buyer. Sgt. Manalo, accompanied by the informer, met appellant, who then produced one tea bag of marijuana. Sgt. Manalo paid appellant with a marked ten-peso bill. Upon a pre-arranged cue, appellant was arrested by other operatives. A body search yielded the marked bill. Appellant then voluntarily surrendered a piece of marijuana cake. Forensic tests confirmed the seized items were marijuana. Procedural History: The Regional Trial Court of Quezon City found the accused guilty beyond reasonable doubt and sentenced him to life imprisonment (30 years) and a fine of P20,000.00, with subsidiary imprisonment in case of insolvency, and to pay the costs. The seized marijuana was ordered confiscated and forfeited in favor of the government. The Petition: The accused appealed to the Supreme Court, contending that the trial court's findings of fact were not supported by or were contrary to the evidence, and that the penalty imposed was disproportionate to the act committed.
Issue(s)
Whether the trial court's findings of fact are supported by the evidence. Whether the penalty imposed is disproportionate to the act committed.
Ruling
The Supreme Court denied the appeal, affirmed the trial court's decision, but ordered the elimination of the phrase '30 years' from the sentence of life imprisonment.
Ratio Decidendi
On the issue of whether the trial court's findings of fact are supported by the evidence: The Court found the appeal devoid of merit, holding that the trial court's findings of fact were in line with and supported by the evidence presented. The Court addressed the appellant's arguments regarding inconsistencies in the testimonies about the marked money, stating that all witnesses concurred it was a ten-peso bill given in exchange for marijuana. Regarding the marking of the money, the Court clarified that marked money can be identified not only by serial numbers but also by chemical treatment, as was done in this case. The Court also dismissed the appellant's argument about the non-presentation of his shorts, stating it was the prosecution's prerogative to present evidence. Furthermore, the Court held that the appellant's bare denial was insufficient to overcome the positive identification by prosecution witnesses. The Court emphasized that the gravamen of the appellant's thesis was that he did not commit the crime, but he offered nothing more than a mere denial. On the issue of whether the penalty imposed is disproportionate to the act committed: The Court found the penalty well within the range provided by law. Section 4 of Article II of RA 6425, as amended by PD 1675, prescribes the penalty of life imprisonment to death and a fine ranging from P20,000.00 to P30,000.00 for the sale, administration, delivery, distribution, or transportation of prohibited drugs. The Court cited People vs. Toledo, where the imposition of life imprisonment with a fine of P25,000.00 for the sale of marijuana was affirmed. Therefore, the Court saw no reason to consider the penalty imposed in the present case as excessive, stating that a drug pusher is a killer without mercy and deserves no mercy.
Main Doctrine
The positive identification by prosecution witnesses of the accused as the perpetrator of the crime, coupled with the recovery of the prohibited drug, is sufficient to establish guilt beyond reasonable doubt, and a bare denial by the accused is not sufficient to overcome such evidence. The penalty imposed for violation of the Dangerous Drugs Act must be within the range provided by law.