People v. Adaya
REITERATIONFacts
The Antecedents: Lt. Joel G. Cantos of NARCOM received information about a certain "Jude" of Poblacion West, Alitagtag, being a marijuana "pusher." An entrapment plan was devised wherein a civilian agent, Rey Alasaas, would pose as a buyer. Alasaas, accompanied by Lt. Cantos, proceeded to "Jude's" residence. Alasaas asked "Jude" (identified as Judrito Adaya) if he had marijuana, to which Adaya responded affirmatively. Alasaas gave Adaya two P5.00 bills with serial numbers SN-PZ992053 and AD-690894, and Adaya handed over one plastic tea bag. Alasaas signaled the backup team by pulling out his shirt. Lt. Cantos arrested Adaya, recovering the marked bills, while the tea bag was retrieved from Alasaas. Laboratory tests confirmed the substance to be marijuana. Procedural History: The Regional Trial Court of Lemery, Batangas, Br. 5, found Judrito Adaya guilty of violating Sec. 4, Art. II of The Dangerous Drugs Act of 1972, sentencing him to reclusion perpetua and a P20,000.00 fine. The accused appealed, claiming innocence, inconsistencies in prosecution testimonies, torture, and a "frame-up." The Petition: The accused-appellant contended that the trial court erred in finding him guilty due to lack of convincing proof and in disbelieving his claims of planted evidence and mauling in the presence of his father and neighbors.
Issue(s)
Whether the guilt of the accused-appellant for illegal sale of marijuana was proven beyond reasonable doubt. Whether the defense of frame-up and torture was sufficiently established. Whether the penalty imposed was correct in light of amendments to R.A. No. 6425.
Ruling
The Supreme Court affirmed the conviction of the accused-appellant for illegal sale of marijuana but modified the penalty. The Court ordered the immediate release of the accused-appellant, considering he had already served the maximum penalty imposed.
Ratio Decidendi
On the guilt of the accused-appellant for illegal sale of marijuana: The Court found the prosecution's evidence sufficient to prove guilt beyond reasonable doubt. The buy-bust operation, as narrated by Lt. Cantos and poseur-buyer Rey Alasaas, was corroborated by the Dangerous Drugs Report confirming the substance as marijuana. The Court gave more weight to the testimony of the NARCOM agents over the accused-appellant's "blanket denial," citing the presumption of regular performance of duty and the absence of any improper motive to falsely accuse the appellant. The Court noted that the accused-appellant's claims of inconsistencies in the prosecution witnesses' testimonies were either trivial or unsubstantiated. On the defense of frame-up and torture: The Court dismissed the defense of frame-up and torture as self-serving and uncorroborated. The accused-appellant failed to present any witness, including his father, to support his claims of being mauled in the presence of his father and neighbors. Furthermore, no medical certificate was presented to prove the alleged beating, nor were the allegedly "bloodied" clothes exhibited. The Court reiterated that in the absence of proof of motive to falsely impute a crime, the presumption of regularity in the performance of official duty and the trial court's findings on credibility prevail. On the correctness of the penalty imposed: The Court modified the penalty based on the retroactive application of Sec. 17 of R.A. No. 7659, which amended Sec. 20 of R.A. No. 6425. For the sale of less than 750 grams of marijuana (1.6261 grams in this case), the penalty prescribed is prision correccional to reclusion temporal without fine. Applying the Indeterminate Sentence Law, the Court imposed a minimum penalty of six (6) months of arresto mayor maximum and a maximum penalty of four (4) years and two (2) months of prision correccional medium. Considering that the accused-appellant had been detained since his arrest in 1987, he had more than served the maximum penalty, thus warranting his immediate release.
Main Doctrine
The Court affirmed the conviction for illegal sale of marijuana, modifying the penalty based on amendments to R.A. No. 6425, and ordered the immediate release of the accused due to time served.