People v. Narito y Sunga
REITERATIONFacts
The Antecedents: On November 10, 1986, Major Vivencio Ramilo received a report about a certain "Aling Edith" selling marijuana in San Pedro, Laguna. A buy-bust operation was planned, with T/Sgt. Perucho as the poseur-buyer and Sgt. Salaria, Delfin Enriquez, and Sgt. Edgar Groyon as back-ups. They proceeded to the location and met a contact man known as "alias Taba," later identified as Alfredo S. Narito. After introducing T/Sgt. Perucho as a buyer, Narito went back to the house and returned with Edith Amado. Edith Amado handed two aluminum foils of marijuana to Narito, who then passed them to T/Sgt. Perucho in exchange for a P20.00 marked bill. Upon seeing the marijuana, T/Sgt. Perucho signaled his back-up. Narito attempted to flee but was apprehended after a struggle. Sgt. Groyon frisked Narito and confiscated another foil of marijuana and the marked bill. Edith Amado escaped during the commotion. Procedural History: The Regional Trial Court of Biñan, Laguna, Branch 25, found Alfredo Narito guilty beyond reasonable doubt of violation of Section 21 in relation to Section 4 of Republic Act No. 6425 (Dangerous Drugs Act of 1972), as amended, and sentenced him to suffer reclusion perpetua, to pay a fine of P30,000.00, and to pay the costs. The confiscated marijuana and marked money were forfeited in favor of the government. The Petition: The accused-appellant appealed the decision, raising two assignments of error: (I) the trial court erred in giving credence to the testimonies of the prosecution witnesses and disregarding the defense theory; and (II) the trial court erred in finding the accused-appellant guilty beyond reasonable doubt.
Issue(s)
Whether the trial court erred in giving credence to the testimonies of the prosecution witnesses and disregarding the defense theory. Whether the trial court erred in finding the accused-appellant guilty beyond reasonable doubt of violation of Republic Act No. 6425.
Ruling
The Supreme Court affirmed the decision of the Regional Trial Court, finding the accused-appellant Alfredo Narito guilty beyond reasonable doubt of violation of Section 21 in relation to Section 4 of Republic Act No. 6425.
Ratio Decidendi
On the credibility of prosecution witnesses and the defense theory: The Supreme Court found the appellant's contentions to be without merit. It is difficult to believe that police operatives would invent a buy-bust operation to charge an innocent person, and there was no reason for them to fabricate their testimonies. The NARCOM operatives were presumed to have regularly performed their duties, acting upon a lawful order, and there was no evidence of any ill motive on their part. The Court reiterated the well-settled rule that findings of the trial court on the credibility of witnesses are entitled to great respect and the highest consideration by appellate courts, as the trial judge had firsthand opportunity to observe their demeanor. The defense of frame-up and extortion was also deemed without merit. The alleged demand for P500.00 occurred after the arrest, meaning the offense had already been consummated and was not determinative of guilt. Furthermore, the defense's theory contained inherent contradictions, such as the differing reasons for the release of appellant and his companion, Rodil Anchoriz, despite both being sons of police officers. The failure to present other companions and the store owner to corroborate the defense's version also raised doubts. On the guilt of the accused-appellant: The prosecution evidence clearly established that during the buy-bust operation, the appellant was apprehended after Edith Amado delivered two aluminum foils of dried marijuana leaves to him, which he then sold to the poseur-buyer for P20.00. The Court found it indubitable that the trial court did not err in finding the appellant guilty of the offense charged on the basis of the evidence on record. The elements of the offense, namely the sale of prohibited drugs, were proven by the prosecution through the buy-bust operation, the confiscation of marijuana, and the positive result of the chemical examination. The conspiracy between Narito and Edith Amado was also evident from their coordinated actions in the transaction.
Main Doctrine
The Court affirmed the conviction of the accused for violation of the Dangerous Drugs Act, holding that the prosecution successfully established guilt beyond reasonable doubt through a buy-bust operation, and that the defense of frame-up and extortion is a common, easily concocted defense that requires extreme caution.