People v. Marco Polo y Fullante
REITERATIONFacts
The Antecedents: Pat. Alfredo Haliva, CIC Jose Reyla, and Sgt. Salvador Aladano went to the Wennen's Snack Bar in San Juan, Metro Manila, based on information that Marco Polo y Fullante was selling marijuana there. They employed a confidential informer as a poseur-buyer, providing P75.00 in marked money. The informer handed the marked money to the appellant, who then left and returned with five aluminum foils containing dried marijuana leaves, which he handed to the informer. CIC Jose Reyla then accosted the appellant, who stated he obtained the marijuana from 'Bobby'. The appellant was brought to Camp Crame for investigation. Procedural History: The Regional Trial Court, Branch CLIX Pasig, Metro Manila, convicted Marco Polo y Fullante for violation of Section 4, Article II of R.A. 6425 (Dangerous Drugs Act), sentencing him to life imprisonment and ordering the confiscation of the marijuana. The court found the accused guilty beyond reasonable doubt. The Petition: The accused-appellant appealed the RTC decision, assigning two errors: (1) that the court a quo erred in not finding him a frame-up victim, and (2) that the court a quo erred in not finding his extrajudicial confession inadmissible in evidence.
Issue(s)
Whether the accused-appellant was a victim of a frame-up. Whether the extrajudicial confession of the accused-appellant is admissible in evidence.
Ruling
The Supreme Court affirmed the judgment of the Regional Trial Court, finding the accused-appellant guilty beyond reasonable doubt of violating Section 4, Article II of Republic Act No. 6425, as amended. The sentence of life imprisonment was upheld, and the confiscation of the marijuana was ordered.
Ratio Decidendi
On the issue of frame-up: The Supreme Court found the claim of frame-up to be a conjecture without serious consideration. While there might have been minor contradictions in the testimonies of prosecution witnesses, these were not on material points. The Court held that the evidence clearly established that the appellant was arrested after selling five aluminum foils of marijuana leaves. The prosecution's narrative, involving information received, the use of a confidential informer as a poseur-buyer, the exchange of money for drugs, and the subsequent arrest, was deemed credible and sufficient. The fact that the marked money was not presented in court did not weaken the prosecution's case, as the transaction was clearly established by testimony. The appellant's own admission that he obtained the marijuana from 'Bobby' further corroborated the prosecution's evidence. The Court emphasized that the arrest occurred in flagrante delicto, meaning in the very act of committing the crime. On the admissibility of the extrajudicial confession: The Supreme Court found the appellant's repudiation of his extrajudicial confession to be without credibility. The confession was prefaced with a clear advisement of his constitutional rights under custodial investigation, including the right to remain silent, the right to counsel (with the offer of a free counsel if he could not afford one), and the warning that his statements could be used as evidence against him. The appellant explicitly understood these rights and voluntarily waived them, agreeing to give a free and voluntary statement without coercion, intimidation, or promises. The Court noted the absence of physical injuries or any complaint of maltreatment, and the detailed nature of the confession, which suggested it was not concocted by the investigator. Therefore, the extrajudicial confession was deemed admissible in evidence. Moreover, the Court stated that even if the confession were disregarded, the other evidence presented by the prosecution was sufficient to prove the appellant's guilt beyond reasonable doubt.
Main Doctrine
The Supreme Court affirmed the conviction of the accused for selling marijuana under R.A. 6425, holding that the prosecution's evidence, including the testimony of the poseur-buyer and the arrest of the accused in flagrante delicto, was sufficient to prove guilt beyond reasonable doubt. The Court also found the extrajudicial confession admissible as the accused was properly apprised of his constitutional rights during custodial investigation and voluntarily waived them.