People v. Constantino
REITERATIONFacts
The Antecedents: Accused Alicia de la Cruz Constantino was apprehended during a buy-bust operation conducted by police operatives in Kalookan City. She was found to be selling methamphetamine hydrochloride, commonly known as "shabu," a regulated drug. Procedural History: An information was filed charging the accused with violation of Section 15, Article III of R.A. No. 6425 (Dangerous Drugs Act of 1972), as amended. The Regional Trial Court (RTC) of Kalookan City found her guilty and sentenced her to life imprisonment and a fine of P20,000.00. The accused appealed the decision. The Petition: The accused appealed to the Supreme Court, arguing that the trial court erred in finding her guilty beyond reasonable doubt and questioning the credibility of the prosecution's lone eyewitness, PO3 Manuel Panlaque. She also contended that the buy-bust operation was flawed and suggested a frame-up.
Issue(s)
Whether the guilt of the accused for selling methamphetamine hydrochloride was proven beyond reasonable doubt. Whether the penalty imposed by the trial court should be modified in light of subsequent amendments to the Dangerous Drugs Act.
Ruling
The Supreme Court affirmed the conviction of the accused but modified the penalty. Accused-Appellant Alicia de la Cruz Constantino was sentenced to suffer an indeterminate penalty ranging from Six (6) months of arresto mayor as minimum to Six (6) years of prision correccional as maximum.
Ratio Decidendi
On the guilt of the accused: The Court found that an actual buy-bust operation was conducted wherein the accused was caught in the act of selling "shabu." While no prior surveillance was conducted, the accused was identified and described by the informer. The Court gave full credit to the prosecution's evidence, noting that the presumption of regularity in the performance of official duty in favor of the arresting officers was not overcome by the accused. The inconsistencies in PO3 Panlaque's testimony were deemed minor and did not affect his credibility, even enhancing it as they indicated honest and unrehearsed responses. The defense of frame-up was given scant consideration as it requires stronger proof and there was no showing of any improper motive on the part of the police officers. The Court reiterated that where there is no evidence of improper motive, the presumption is that the witnesses were not impelled by such and their testimonies are entitled to full faith and credit. The Court was convinced that the guilt of the accused was proved beyond reasonable doubt. On the modification of the penalty: The Court noted the amendments introduced by R.A. No. 7659 to R.A. No. 6425. Specifically, Section 15 of R.A. No. 6425, as amended by R.A. No. 7659, changed the penalty for selling methamphetamine hydrochloride. The Court applied the ruling in People vs. Martin Simon y Sunga, which held that provisions of R.A. No. 7659 favorable to the accused shall be given retroactive effect. The Court determined that since the quantity of shabu sold was only 0.01 gram, which is less than the quantities specified in the first paragraph of the amended Section 20 of R.A. No. 6425, the imposable penalty should range from prision correccional to reclusion temporal. Applying the Indeterminate Sentence Law, the accused was sentenced to an indeterminate penalty from six (6) months of arresto mayor as minimum to six (6) years of prision correccional as maximum.
Main Doctrine
The Court affirmed the conviction for selling methamphetamine hydrochloride but modified the penalty based on the quantity of the drug involved and the amendments introduced by R.A. No. 7659, applying the Indeterminate Sentence Law.