People v. Mirantes
REITERATIONFacts
The Antecedents: Accused-appellant Jesus Mirantes was convicted by the Regional Trial Court of Lanao del Norte for violation of Section 4, Article II of Republic Act No. 6425 (Dangerous Drugs Act of 1972). He was charged with conspiring with Guarberto Balolong in selling, transporting, and delivering two sticks of marijuana cigarettes on September 13, 1988, in Iligan City. The prosecution alleged that NARCOM agents conducted a buy-bust operation where Celso Engkig acted as the poseur-buyer, giving a five-peso bill to Mirantes in exchange for two sticks of marijuana. Upon consummation, Mirantes and Balolong were arrested, and the marijuana sticks and marked bill were seized. Mirantes denied ownership of the marijuana, claiming it was attributed to Balolong by the NARCOM agents who compelled him to sign a receipt and other documents without counsel. Procedural History: The Regional Trial Court convicted Jesus Mirantes for violation of the Dangerous Drugs Act, imposing reclusion perpetua and a fine. Mirantes appealed the decision. The Petition: The accused-appellant contended that the trial court erred in giving absolute credence to the prosecution witnesses' testimonies, which he found improbable and inconsistent; in appreciating the seizure receipt signed without assistance of counsel during custodial investigation; and in convicting him despite the existence of reasonable doubt.
Issue(s)
Whether the trial court erred in giving absolute credence to the prosecution witnesses' testimonies. Whether the seizure receipt signed by the appellant without the assistance of counsel during custodial investigation is admissible. Whether the guilt of the accused-appellant was established beyond reasonable doubt.
Ruling
The Supreme Court reversed and set aside the judgment of the Regional Trial Court, acquitting the accused-appellant Jesus Mirantes on the ground of reasonable doubt.
Ratio Decidendi
On the credibility of prosecution witnesses: The Supreme Court found substantial inconsistencies in the testimonies of the prosecution witnesses, particularly Pat. Edgardo Englatiera, regarding the composition of the buy-bust team and the recovery of the marijuana. Englatiera's testimony was adopted by the trial court, which included Guarberto Balolong, the co-accused, as part of the buy-bust team, a perplexing circumstance never explained by the prosecution. Furthermore, there were apparent vacillations in Englatiera's testimony concerning from whom the marijuana was recovered, oscillating between the appellant and the poseur-buyer. These contradictions and inconsistencies, involving material aspects of the case, cast serious doubts on the veracity of the prosecution's cause and the reliability of the witness's powers of observation and recall. The Court reiterated that while trial court findings on credibility are generally respected, deviations are allowed when substantial facts are overlooked or when there are inconsistencies on material matters. On the admissibility of the seizure receipt: The Supreme Court agreed with the appellant that the seizure receipt signed by him without the assistance of counsel during custodial investigation was inadmissible. The Court noted that it is unusual for an accused to sign receipts for items allegedly taken from him; instead, the confiscating officers should sign. This act was deemed a violation of the appellant's constitutional rights to remain silent and to counsel, rendering any confession obtained thereby inadmissible in evidence. Therefore, the seizure receipt could not be made the basis of the appellant's conviction. On reasonable doubt: The Court found further dubiety in the prosecution's case due to the contradicting testimony of the poseur-buyer, Celso Engkig, regarding the location of the appellant at the time of the alleged transaction. Engkig claimed he saw the appellant inside a house, while other witnesses placed him outside. Moreover, Engkig's version of the transaction, where the suspected drug dealer allegedly initiated the offer to smoke marijuana like a "sidewalk hawker," was considered contrary to human nature and experience, especially since the appellant was aware of the consequences of drug trafficking, having a brother previously apprehended for the same offense. The Court emphasized that the presumption of regularity in the performance of official functions cannot overcome the constitutional presumption of innocence, especially when the prosecution's evidence is weak and replete with inconsistencies. The prosecution must establish guilt beyond reasonable doubt, which it failed to do in this case.
Main Doctrine
Conviction cannot be based on inconsistent and contradictory testimonies of prosecution witnesses, nor on evidence obtained in violation of the accused's constitutional rights. Reasonable doubt necessitates acquittal.