People v. Cañeja
REITERATIONFacts
The Antecedents: An Information was filed on January 29, 1991, charging Manuel Cañeja y Ilas with violation of Section 15, Article III of R.A. No. 6425 (Dangerous Drugs Act of 1972), as amended, for allegedly selling 0.0958 grams of shabu to a poseur-buyer on January 26, 1991, in Manila. Procedural History: The accused pleaded not guilty. During pre-trial, the parties admitted the accused's identity, the genuineness of certain documents, the submission of Exhibit "C-1" for examination which was found positive for methamphetamine hydrochloride, and that the police lacked a search warrant or arrest warrant at the time of arrest. After trial, the Regional Trial Court (RTC), Branch 5, Manila, rendered a judgment of conviction on March 31, 1992, sentencing the accused to life imprisonment and a fine of P20,000.00. The Petition: The accused appealed the RTC decision, assigning as errors the trial court's reliance on the allegedly contradicting and improbable testimony of the poseur-buyer and its failure to prove guilt beyond reasonable doubt. The appellant argued that the decision was based on speculation and that his claim of being mauled by the police was not rebutted. The appellee recommended affirmance, stating that any alleged inconsistencies in the poseur-buyer's testimony were immaterial and that the conviction was based on being caught in flagrante delicto, not on a confession.
Issue(s)
Whether the guilt of the accused was proven beyond reasonable doubt. Whether the penalty imposed by the trial court should be modified in light of subsequent amendments to R.A. No. 6425.
Ruling
The Court affirmed the conviction of the accused-appellant but modified the penalty. The accused-appellant 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 the testimony of the poseur-buyer, Joel Ubago, to be consistent and credible. His account of the buy-bust operation was corroborated by Pat. Edmund Usita. Ubago testified that he volunteered to act as the poseur-buyer upon hearing that the accused, alias "Resty," was selling drugs. He successfully purchased shabu from the accused using marked money, which was later confirmed by NBI examination to be methamphetamine hydrochloride. The "Booking Sheet and Arrest Report" also supported this fact. The Court noted that Ubago's answers during cross-examination enhanced his credibility, and there was no evidence of any ulterior motive for him to impute a criminal offense upon the appellant. The Court also addressed the appellant's claim of being mauled by the police, stating that it was a belated claim, unsupported by medical examination, and crucially, the conviction was not based on any confession but on being caught in flagrante delicto. On the modification of the penalty: The Court acknowledged the amendments introduced by R.A. No. 7659 to Section 15 and Section 20 of R.A. No. 6425. It cited People vs. Martin Simon y Sunga which held that provisions of R.A. No. 7659 favorable to the accused should be given retroactive effect. The Court determined that since the quantity of shabu involved (0.0958 gram) was less than the quantities specified in the first paragraph of the amended Section 20, the imposable penalty should range from prision correccional to reclusion perpetua. However, applying the ruling in People vs. Martin Simon y Sunga, the penalty should range from prision correccional to reclusion temporal. Further applying the Indeterminate Sentence Law, the accused could be 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 violation of R.A. No. 6425, as amended, 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.