People v. Lakibul
REITERATIONFacts
The Antecedents: On November 6, 1988, NARCOM agents received information about a drug pusher at Lower Calarian, Zamboanga City. Surveillance was conducted on November 6, 7, and 8, 1988, observing several teenagers going to the suspected pusher. On November 8, 1988, a buy-bust operation was planned. A team composed of TSgt. Dalumpines (team leader), SSgt. Dedicatoria, and PO2 Manuel S. Alarcon, Sr. (poseur-buyer) was formed. TSgt. Dalumpines marked two five-peso bills (serial numbers JD 426621 and JM 36075) for the operation. The team proceeded to Lower Calarian. PO2 Alarcon approached the suspect, identified by TSgt. Dalumpines, and expressed a desire to buy P10.00 worth of marijuana. The suspect produced two newspaper-wrapped articles from his pocket. PO2 Alarcon examined the contents, confirmed they were marijuana, and gave the marked bills to the suspect. PO2 Alarcon then gave the pre-arranged signal, and TSgt. Dalumpines arrested the suspect. The two newspaper-wrapped marijuana articles were turned over to TSgt. Dalumpines, and the suspect was brought to the NARCOM Office, where he identified himself as Utoh Lakibul. The marked bills were recovered from the appellant after a body search. Laboratory tests confirmed the contents of the wrappers were marijuana. Procedural History: An Information was filed on November 8, 1988, charging Utoh Lakibul y Daud with violation of Section 4, Article II of Republic Act No. 6425 (Dangerous Drugs Act). The accused pleaded not guilty. After trial, the Regional Trial Court of Zamboanga City, Branch 12, found the accused guilty beyond reasonable doubt and sentenced him to life imprisonment and a P20,000.00 fine. The Petition: The accused appealed the decision, assigning errors concerning the trial court's reliance on Exhibit "F" (marked bills), its failure to believe the accused's testimony corroborated by his witnesses, and its reliance on prosecution witnesses over defense evidence.
Issue(s)
Whether the trial court erred in basing its decision on Exhibit "F" of the prosecution. Whether the trial court erred in not believing the testimony of the accused/appellant as corroborated by his three witnesses, and whether the trial court erred in relying on the testimony of the prosecution witnesses instead of weighing the evidence adduced in favor of the accused/appellant. Whether any alleged inconsistencies in the testimonies of the prosecution witnesses were substantial enough to impair the veracity of their narration.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court in toto, finding no reversible error. The accused-appellant, Utoh Lakibul y Daud, was found guilty beyond reasonable doubt of violating Section 4, Article II of Republic Act No. 6425, and his sentence of life imprisonment and a P20,000.00 fine was upheld.
Ratio Decidendi
On the issue of Exhibit "F" and the marked bills: The Court found no mistake as to the identity of the marked bills presented by the prosecution. The testimony of PO2 Alarcon clearly identified the serial numbers of the two five-peso bills used in the buy-bust operation. Furthermore, the Court reiterated that even without the marked money, the crime of selling marijuana is consummated by the delivery of the prohibited drug to the police officer acting as a poseur-buyer, provided the police officer went through the motions of a buyer and the suspect accepted the offer and delivered the goods. The Court cited People vs. De la Cruz (191 SCRA 160 [1990]) in support of this principle. On the credibility of witnesses and the weight of evidence: The Court held that the findings of the trial court on the credibility of witnesses are entitled to great weight on appeal. The trial court is in a better position to assess credibility, having observed the witnesses' demeanor and manner of testifying. The Court found no reason to deviate from this rule, agreeing with the trial court's assessment that the prosecution witnesses were more credible than the defense witnesses. The trial court's reasons included observing the sincerity and truthfulness of the government witnesses, noting that the defense witnesses were long-time neighbors of the accused and testified at the request of his mother, and finding the defense witnesses' testimonies to be more elaborate than the accused's own testimony. The Court also highlighted the absence of any ascribed evil or ulterior motive for the NARCOM agents to arrest the accused without reason, as there was no prior misunderstanding or trouble between them. On alleged inconsistencies: The Court found that any alleged inconsistencies in the testimonies of the prosecution witnesses were not substantial enough to impair the essential veracity of their narration that the accused was caught in flagrante delicto selling marijuana during the buy-bust operation. The core of their testimony, which established the consummation of the crime, remained intact and credible.
Main Doctrine
The Court affirmed the conviction for violation of the Dangerous Drugs Act, holding that the prosecution sufficiently established the elements of the crime through a valid buy-bust operation and that the trial court's assessment of witness credibility was entitled to great weight.