People v. Manahan
REITERATIONFacts
The Antecedents: On May 28, 1989, accused-appellant Julio Manahan was charged with violation of Section 4, Article II of Republic Act No. 6425 (Dangerous Drugs Act of 1972), for allegedly selling 5.13 grams of marijuana fruiting tops in consideration of P20.00 to a poseur-buyer. The operation was conducted by a buy-bust team from the San Mateo Police. Procedural History: The Regional Trial Court of San Mateo, Rizal, Branch 76, found Manahan guilty and sentenced him to fourteen (14) years, eight (8) months, and one (1) day to seventeen (17) years and four (4) months imprisonment, and a fine of P12,000.00. On appeal, the Court of Appeals affirmed the conviction but modified the penalty to life imprisonment and increased the fine to P25,000.00. The case was certified to the Supreme Court due to the penalty imposed. The Petition: Accused-appellant Manahan raised the sole assignment of error that the Court of Appeals gravely erred in convicting him and modifying the penalty to life imprisonment and increasing the fine, despite allegedly weak and incredible testimonies of prosecution witnesses.
Issue(s)
Whether the Court of Appeals gravely erred in convicting the accused-appellant and modifying the penalty imposed by the trial court; and whether the penalty imposed by the Court of Appeals, and subsequently modified by the Supreme Court, is proper. Whether the alleged inconsistencies in the testimonies of prosecution witnesses render their testimonies weak and incredible. Whether the presumption of regularity in the performance of duty of law enforcement officers applies in this case.
Ruling
The decision of the Court of Appeals is AFFIRMED WITH MODIFICATION as regards the penalty imposed. The accused-appellant is sentenced to suffer imprisonment from six (6) months of arresto mayor, as minimum, to two (2) years and four (4) months of prision correccional, as maximum. The fine of P25,000.00 is deleted.
Ratio Decidendi
On the modification of the penalty: The Supreme Court noted that the Court of Appeals correctly modified the penalty to life imprisonment based on the original Section 4 of R.A. No. 6425. However, the Court applied the amendatory provisions of Republic Act No. 7659, which introduced changes to Section 20 of R.A. No. 6425. Since the quantity of marijuana involved (5.13 grams) was less than the 750 grams threshold specified in the amended Section 20 for the imposition of reclusion perpetua to death, the penalty should range from prision correccional to reclusion perpetua depending on the quantity. Applying the Intermediate Sentence Law and citing People vs. Martin Simon and People vs. Martinez, the Court imposed the penalty of six (6) months of arresto mayor, as minimum, to two (2) years and four (4) months of prision correccional, as maximum, and deleted the fine. On the alleged inconsistencies in prosecution witnesses' testimonies: The Supreme Court reiterated the well-entrenched rule that findings of the trial court on the credibility of witnesses are accorded great weight and respect on appeal. While minor inconsistencies were noted between the testimonies of Pfc. Alberto and Pfc. dela Rosa regarding the informant's presence, the exchange of money and drugs, and the source of the marked money, these were deemed minor details that do not destroy the probative value of their testimonies. The Court held that such inconsistencies are normal infirmities resulting from individual differences in appreciating events and may even bolster the credibility of witnesses as badges of candor, citing People vs. Gamboa and People vs. Lagota. The core fact of the sale of marijuana was clearly established, which is the essential element for conviction in drug sale cases, as held in People vs. Alilin. On the presumption of regularity in the performance of duty: The Court found scant consideration in Manahan's arguments contesting the application of the presumption of regularity to the police officers. The presumption holds that law enforcement officers regularly performed their duties in the absence of proof to the contrary, as established in People vs. Khan. The Court found nothing in the records to suggest that the police officers had any motive other than to perform their duty. The absence of prior surveillance records, the failure to properly mark the money, and the non-presentation of the confidential informant were deemed immaterial. The Court has consistently ruled that there is no fixed procedure for buy-bust operations, and the testimony of a confidential informant is not indispensable when the poseur-buyer's testimony is sufficient, citing People vs. Cruda, People vs. Castiller, People vs. Mangusan, People vs. Carpio, and People vs. Bagawe.
Main Doctrine
Minor inconsistencies in the testimonies of prosecution witnesses do not necessarily impair their credibility, especially when the core fact of the illegal sale of prohibited drugs is established beyond reasonable doubt. The presumption of regularity in the performance of official duty by law enforcement officers prevails in the absence of proof of ill motive or contrary evidence.