People v. Ruelo
REITERATIONFacts
The Antecedents: Edilberto Ruelo y Lahaylahay was accused of violating Sections 15 and 16 of R.A. 6425 (Dangerous Drugs Act of 1972), as amended, for selling and possessing shabu. The charges were consolidated. The prosecution presented evidence that on February 16, 1991, police received a tip about the accused's drug-pushing activities at the Las Palmas Hotel. After four nights of surveillance, the police confirmed the information. On February 23, 1991, a buy-bust operation was conducted. Pat. Victor Guinto acted as the poseur-buyer, using marked P100-bills. The accused allegedly sold three decks of shabu and was found in possession of four more. The substance was later confirmed by NBI to be methamphetamine hydrochloride. The defense claimed the accused was apprehended by two men, identified as Patrolmen Victor Guinto and Mario Montes, while washing his socks at the JJC Apartelle. They allegedly kicked him, pushed him to his room, searched it without a warrant, and seized his belongings, including P2,000.00. The defense also alleged demands for ransom and maltreatment at the police station. Procedural History: The Regional Trial Court of Manila rendered a decision on October 4, 1991, finding the accused guilty as charged. The court imposed life imprisonment and a fine of P30,000.00 for selling shabu, and an indeterminate prison term of six (6) years and one (1) day to twelve (12) years and a fine of P10,000.00 for possessing shabu. The Petition: The accused appealed the decision, imputing error to the trial court in its findings regarding the credibility of witnesses, the absence of ill motive on the part of the policemen, the identification of arresting officers, the truthfulness of police testimony, and the credibility of defense witnesses.
Issue(s)
Whether the trial court erred in giving credence to the testimony of the prosecution witness despite the alleged lack of corroboration. Whether the defense of frame-up and extortion was sufficiently proven. Whether the accused was properly apprehended and his rights were violated. Whether the penalty imposed by the trial court should be modified in light of R.A. 7659.
Ruling
The Supreme Court affirmed the judgment of conviction with modification of the penalty. The Court found the evidence of the prosecution to be credible and sufficient to prove the guilt of the accused beyond reasonable doubt. The defense's claims of frame-up and extortion were found to be unsubstantiated and uncorroborated. The Court also modified the penalty based on the retroactive application of R.A. 7659.
Ratio Decidendi
On the credibility of witnesses and the alleged frame-up/extortion: The Court reiterated the doctrine that the findings of the trial court on the credibility of witnesses are entitled to great weight and respect. The appellant's claim of frame-up and extortion was not substantiated by any credible evidence. The Court noted that the appellant failed to present any evidence of improper motive on the part of the apprehending officers. Furthermore, the appellant's common-law wife's attempt to bribe Cpl. Suralvo, which was not denied, weakened the defense's claims. The Court also found inconsistencies in the defense's narrative, particularly regarding the participation of Pat. Montes and the number of responding policemen. The Court held that the testimony of a single credible witness is sufficient to convict. In this case, the testimony of Pat. Guinto, corroborated by the physical evidence and the findings of the NBI, satisfied the quantum of proof required. The defense's version of events was found to be dubious and uncorroborated. On the alleged violation of rights and improper apprehension: The Court found that the arrest was conducted in accordance with law, following a confirmed buy-bust operation where the appellant was caught in flagrante delicto selling shabu. The prosecution's evidence, including the recovery of marked money and the positive laboratory examination of the confiscated substances, was deemed sufficient. The appellant's claims of maltreatment were not substantiated by medical certificates, and his explanation for the delay in filing charges was unconvincing. The Court also pointed out that the appellant did not complain of maltreatment to the Inquest Fiscal. On the sufficiency of evidence: This issue is addressed in the first ratio point. On the modification of penalty: The Court applied the amendatory provisions of R.A. 7659 retroactively, as they were favorable to the accused. Considering the quantities of shabu involved (less than a gram in both cases), the Court applied the second paragraph of Section 20 of R.A. 6425, as amended, which prescribes a penalty ranging from prision correccional to reclusion temporal. Applying the Indeterminate Sentence Law, the Court imposed an indeterminate prison term of four (4) months and twenty (20) days of arresto mayor maximum as minimum, to three (3) years and two (2) months of prision correccional medium as maximum, for each case.
Main Doctrine
The testimony of a single witness, if credible and positive, is sufficient to convict, provided it satisfies the court beyond reasonable doubt. The findings of the trial court on the credibility of witnesses are entitled to great weight and respect unless some material facts have been overlooked or misconstrued.