People v. Atad
REITERATIONFacts
The Antecedents: Accused-appellant James Atad y Cuizon was charged with violation of Section 4, Article II of Republic Act No. 6425 (Dangerous Drugs Act) for allegedly selling marijuana. The prosecution presented SPO4 Renato Salazar, the NARCOM agent who led the buy-bust operation, and Bernabe Aringa, the forensic chemist. Salazar testified that based on surveillance reports, a buy-bust operation was organized. He stated that the poseur-buyer, Arnesto Geronggay, handed marked money to Atad, who then left and returned, handing over marijuana joints. Upon signaling, the team arrested Atad and confiscated a half-consumed marijuana joint. Aringa confirmed that the six joints and the half-consumed stick were positive for marijuana. Procedural History: The Regional Trial Court of Lanao del Norte, Branch 4, found the accused guilty beyond reasonable doubt and sentenced him to life imprisonment and a fine of P20,000.00. The Petition: The accused appealed the decision, questioning the credibility of the lone prosecution witness (SPO4 Salazar) when contradicted by the poseur-buyer (Geronggay), and the sufficiency of the prosecution's evidence.
Issue(s)
Whether or not the testimony of the lone and uncorroborated witness of the prosecution should be given credence when the poseur-buyer refuted the said testimony. Whether or not the evidence of the prosecution was sufficient to prove the guilt of the accused-appellant for violation of Section 4, Article II of Republic Act No. 6425, particularly of selling marijuana, beyond reasonable doubt, when receipt of the marijuana joints allegedly seized from the accused-appellant was not admitted in evidence by the court a quo.
Ruling
The Supreme Court affirmed the conviction of the accused-appellant but modified the penalty. The Court held that the testimony of SPO4 Renato Salazar was credible, while the testimony of the poseur-buyer, Arnesto Geronggay, was full of inconsistencies and contradictions, rendering it unreliable. The Court found that the prosecution sufficiently proved the illegal sale of marijuana through Salazar's eyewitness account, despite the inadmissibility of the receipt signed by the accused during custodial investigation without counsel. The penalty was reduced in accordance with amendments to RA 6425 and jurisprudence.
Ratio Decidendi
On the credibility of the lone prosecution witness versus the poseur-buyer: The Court found no substantial reason to overturn the trial court's findings regarding the credibility of witnesses. SPO4 Renato Salazar's testimony was found to be credible, as he had no apparent motive to falsely implicate the accused, and his actions in preparing for the buy-bust operation, including authenticating the money, indicated a genuine intent to apprehend a drug peddler. In contrast, the poseur-buyer, Arnesto Geronggay, presented a testimony riddled with inconsistencies on material points, including contradictory accounts of the timeline of events, his presence at the scene, and his relationship with the accused. The Court noted that Geronggay's testimony was not only inconsistent but also illogical, such as claiming to have bought marijuana twice from the same suspect on the same day without the police team being present for entrapment. The Court reiterated the rule that findings of trial courts on credibility are given great weight and respect, especially when the judge had the opportunity to observe the witnesses' demeanor. On the sufficiency of the prosecution's evidence: Despite the inadmissibility of the receipt signed by the accused-appellant during custodial investigation without the presence of counsel, the Court found that the prosecution had sufficiently proven the criminal act of selling marijuana. SPO4 Salazar's direct eyewitness testimony, wherein he saw the accused-appellant hand over marijuana joints to the poseur-buyer after receiving marked money, was deemed sufficient. The Court emphasized that the commission of the offense of illegal sale of prohibited drugs requires only the consummation of the selling transaction, which occurs the moment the buyer receives the drug from the seller. The forensic chemist's positive findings for marijuana further corroborated the testimony. The Court concluded that the evidence presented established the guilt of the accused-appellant beyond reasonable doubt.
Main Doctrine
The uncorroborated testimony of a police officer in a drug buy-bust operation can be given credence, especially when the poseur-buyer's testimony is riddled with inconsistencies and contradictions, and the police officer has no apparent motive to falsely implicate the accused. The commission of the offense of illegal sale of prohibited drugs requires merely the consummation of the selling transaction, which occurs the moment the buyer receives the drug from the seller.