People v. David
REITERATIONFacts
The Antecedents: On June 12, 1990, NARCOM agents conducted an entrapment operation in Angeles City against a person known as "Butch." Pfc. Lauro Mamac acted as the poseur-buyer and approached the accused, Winifred David @ "Butch," after being pointed to him. Pfc. Mamac expressed his desire to buy marijuana, and the accused, after asking for the quantity, left and returned with two small plastic bags of marijuana. Pfc. Mamac paid the accused with marked bills and gave a prearranged signal. Pfc. Ibay, Pfc. Cruz, and Pfc. Arimbuyutan then arrested the accused, recovering the marked bills from him. The contents of the plastic bags were examined by Maj. Marlene Salangad and found to be positive for marijuana. Procedural History: The accused was charged with violation of Section 4, Article II of R.A. No. 6425 (Dangerous Drugs Act). He pleaded not guilty. The prosecution presented several NARCOM agents and a forensic chemist. The defense presented the accused and his brother, who claimed the accused was framed and that marijuana was planted on him. On rebuttal, Pfc. Danilo Cruz denied the defense's claims. The Regional Trial Court (RTC), Branch 57, Angeles City, rendered a decision on July 30, 1991, finding the accused guilty beyond reasonable doubt and sentencing him to life imprisonment and a fine of P20,000.00. The Petition: The accused appealed the RTC decision to the Supreme Court, raising the sole assignment of error that the trial court gravely erred in convicting him by disregarding the defense evidence.
Issue(s)
Whether the accused was induced to commit the crime, and whether evidence of inducement, discovered after promulgation, can be considered. Whether the accused's claim of being framed is credible. Whether the positive testimonies of NARCOM agents in a buy-bust operation are sufficient to establish guilt beyond reasonable doubt, and on the validity of the entrapment operation. On the admissibility and sufficiency of prosecution evidence.
Ruling
The Supreme Court dismissed the appeal and affirmed the decision of the Regional Trial Court, finding the accused guilty beyond reasonable doubt of the violation of Section 4, Article II of R.A. No. 6425.
Ratio Decidendi
On the issue of inducement and newly discovered evidence: The Court held that the issue of inducement, raised for the first time on appeal based on information allegedly received after promulgation, could not be considered. The Rules of Court explicitly state that no evidence which has not been formally offered shall be considered. Furthermore, the alleged inducement was known to the accused himself even before arraignment or during trial, and his failure to disclose this to his counsel for the formulation of his defense strategy meant it did not qualify as newly discovered evidence. The Court also noted that if the accused's wife were to testify about his alleged confession, it would be hearsay evidence, inadmissible or of little probative value. On the credibility of the defense of being framed: The Court found the accused's claim of being framed unmeritorious. The defense's argument that a drug pusher would not sell in a public place was rejected, as the Court has consistently ruled that small-time drug pushers sell to anyone with money, and the location does not deter them from their illegal trade. The Court emphasized that the positive testimonies of the NARCOM agents, who had no established improper motive, deserved full faith and credit, and they are presumed to have regularly performed their duties. On the validity of the entrapment operation: The Court was convinced that what transpired was a legitimate entrapment operation, an effective method of apprehending drug peddlers. The positive testimonies of the NARCOM agents, who were not shown to have any ulterior motive, were given full faith and credit. The sweeping accusations made by the defense counsel against law enforcers were deemed unfounded and irresponsible due to the lack of proof. On the sufficiency of prosecution evidence: The Court found the prosecution's evidence sufficient to establish the guilt of the accused beyond reasonable doubt. The buy-bust operation was conducted properly, the sale and delivery of marijuana were consummated, and the confiscated marijuana was proven to be a prohibited drug. The testimonies of the NARCOM agents were consistent and corroborated by the physical evidence. On the admissibility of evidence: The Court reiterated the principle that only evidence formally offered during trial can be considered by the court. The defense counsel's failure to formally offer the alleged evidence of inducement meant it could not be given any weight. The Court also pointed out that the accused's own representation of being induced, if true, was known to him and should have been presented during the trial.
Main Doctrine
The positive testimonies of law enforcement officers in entrapment operations, against whom no improper or ulterior motive is established, deserve full faith and credit. Accusations of being framed or induced, without proof, are insufficient to overturn such testimonies. Evidence not formally offered during trial cannot be considered.