People v. Dag-uman
REITERATIONFacts
The Antecedents: On October 3, 1989, members of the Narcotics Unit conducted a buy-bust operation in Ozamiz City. Using a civilian informer as a poseur buyer, they gave marked P5.00 bills to the informer to purchase marijuana from the accused, Joel Dag-uman. The accused handed over six (6) sticks of handrolled marijuana cigarettes to the poseur buyer and received the marked bills. Upon arrest, the accused was found with the marked bills and an additional ten (10) sticks of handrolled marijuana cigarettes. The confiscated marijuana was confirmed by laboratory examination. Procedural History: The Regional Trial Court (RTC) of Ozamiz City convicted Joel Dag-uman for violation of Section 4, Article II of Republic Act No. 6425 (Dangerous Drugs Act of 1972), as amended. He was sentenced to reclusion perpetua and a fine of P20,000.00. The RTC found the prosecution's evidence credible and the accused's defense of inducement unworthy of belief. The Petition: The accused appealed his conviction, arguing that his version of events, which claimed inducement by Narcom agents, should have been believed, and alternatively, that he should have been credited with the full period of his preventive imprisonment.
Issue(s)
Whether the accused was guilty beyond reasonable doubt of violating the Dangerous Drugs Act. Whether the accused's defense of inducement, alleging he was compelled to buy marijuana, was credible. Whether the accused should have been credited with the full period of his preventive imprisonment.
Ruling
The Supreme Court affirmed the conviction of the accused for violation of the Dangerous Drugs Act, with a modification in the sentence. The Court ruled that the accused should be sentenced to life imprisonment instead of reclusion perpetua. The RTC's decision regarding the crediting of preventive imprisonment was also affirmed.
Ratio Decidendi
On the guilt of the accused: The Court found the evidence of the prosecution, particularly the buy-bust operation and the arrest of the accused in flagrante delicto, to be credible and sufficient to establish guilt beyond reasonable doubt. The police officers' testimony regarding the transaction, the use of marked bills, and the recovery of marijuana and the marked money from the accused's person was given full faith and credit. The Court noted the presumption that public officers regularly perform their duties and the absence of any motive for the arresting officers to falsely incriminate the accused. The Court found the accused's admission of no prior acquaintance with the arresting officers further negated any theory of a "frame-up." On the defense of inducement: The Supreme Court rejected the accused's defense of inducement, characterizing his story as "inherently improbable" and a "feebly contrived attempt to explain away his possession of marijuana and his act of selling it." The Court found his narrative of being compelled by strangers to buy marijuana for P15.00 to be "too naive to be believed" and contrary to human experience. The Court emphasized that the accused was aware that buying or selling marijuana was prohibited by law, yet he readily consented to the illegal act when approached by persons he barely knew, without any substantial showing of undue pressure beyond the alleged P15.00. On the crediting of preventive imprisonment: The Court affirmed the RTC's ruling that the accused could only be credited with four-fifths (4/5) of his preventive imprisonment. The Court reiterated that full credit is given only if the accused has voluntarily agreed in writing to abide by the same disciplinary rules imposed on convicted prisoners, as provided by law (Republic Act 6127). Since the accused did not agree in writing to abide by such rules, he was only entitled to the fractional credit.
Main Doctrine
The Supreme Court affirmed the conviction of the accused for violation of the Dangerous Drugs Act, holding that the evidence of entrapment through a buy-bust operation was credible and that the accused's defense of inducement was improbable. The Court also clarified the crediting of preventive imprisonment.