Title
People vs. Aranda y Doria
Case
G.R. No. 100985
Decision Date
Sep 17, 1993
Teresita Aranda acquitted of drug charges due to inconsistent testimonies, lack of proof of delivery, and insufficient evidence establishing guilt beyond reasonable doubt.

Case Digest (G.R. No. 145855)
Expanded Legal Reasoning Model

Facts:

  • Case Background and Nature of the Offense
    • The case involves People of the Philippines versus Teresita Aranda y Doria for violating Section 15, Article III of the Dangerous Drugs Act (R.A. No. 6425, as amended).
    • The trial took place in the Regional Trial Court, Branch 124, Kalookan City, where appellant Teresita Aranda was found guilty beyond reasonable doubt of delivering methamphetamine hydrochloride ("shabu").
    • The information charged that on August 17, 1990, in Kalookan City, appellant wilfully, unlawfully, and feloniously sold and delivered two small white transparent plastic bags containing methamphetamine hydrochloride to a tricycle driver, Benito Villanueva.
  • Facts Favorable to the Prosecution
    • On the said date, at around 5:00 p.m., an informant telephoned Pfc. Alexander Corpuz of the Anti-Narcotics Unit at the Kalookan City Police Station, reporting that a tricycle driver (Plate No. NM-4831) was about to buy "shabu" from Teresita Aranda.
    • Lt. Eliseo de Leon organized a team composed of Pfc. Corpuz, Pfc. Elmario Adelante, and Pat. Romeo Sengco to monitor the area.
    • The police, having arrived at the designated location along the intersection of Reparo and Gen. Tinio Streets, observed the arrival of a tricycle matching the description.
    • Teresita Aranda was seen coming out of a compound and approaching the tricycle alone while carrying a shoulder bag.
    • Just before boarding the tricycle, she handed over what appeared to be small plastic bags to the driver, later identified as Benito Villanueva.
    • As the transaction unfolded, Pfc. Adelante intervened by seizing the plastic bags from Villanueva’s grasp and shouting, “Sila’y positive. Positive yan.”
    • Pat. Sengco corroborated by asking Teresita Aranda to open her right hand, uncovering an additional small plastic bag containing suspected methamphetamine hydrochloride.
    • The apprehension occurred promptly, and the suspects were taken by Pfc. Corpuz in his jeep to the Kalookan City Police Station for further investigation.
  • Appellant’s Version of Events
    • Teresita Aranda testified that on the afternoon of August 17, 1990, she was returning from a friend’s house in Bagong Barrio, Kalookan City, and boarded a tricycle along Reparo Street en route to her residence in Pasay City.
    • According to her version, police suddenly appeared and arrested the tricycle driver—whom she later identified as Benito Villanueva—and subsequently forced her to alight and be taken for questioning.
    • She further contended that at the time of her arrest there was no warrant, she was not informed of the grounds for her detention, and that during the incident she was separated from Villanueva.
    • Additional claims include an allegation that a police officer (identified in her brief as Pfc. Corpuz) asked her for money during the proceedings at the police headquarters.
  • Trial Court Judgment and Evidence Presented
    • On June 13, 1991, the trial court found Teresita Aranda guilty beyond reasonable doubt and sentenced her to suffer life imprisonment, pay a fine of P20,000.00, and shoulder the costs of the proceeding.
    • The court ordered the forfeiture of the two plastic transparent bags (Exhibits “F” and “G”) containing the suspected dangerous drug, to be turned over to the Dangerous Drugs Board.
    • The prosecution’s case was largely dependent on the testimonies of the apprehending officers (Pfc. Corpuz, Pfc. Adelante, and Pat. Sengco) despite noted discrepancies in their accounts.
    • A significant aspect of the evidence was the testimony of Benito Villanueva, who upon examination stated that nothing had been delivered to him by the appellant—a point that undermined the prosecution’s charge.

Issues:

  • Credibility and Consistency of Witness Testimonies
    • Whether the discrepancies among the testimonies of the apprehending officers (Corpuz, Adelante, and Sengco) affected the foundation of the prosecution’s case.
    • The impact of conflicting accounts regarding the sequence of events, including the identification of the investigator and the specifics about the condition and handling of the plastic bags.
  • Reliability of the Prosecution Witness
    • Whether Benito Villanueva, whose testimony ultimately negated the delivery of drugs by the appellant, should have been considered a hostile witness.
    • The admissibility and weight to be given to Villanueva’s testimony, considering that he was not declared hostile pursuant to Section 12, Rule 132 of the Rules on Evidence.
  • Establishment of the Essential Elements of the Offense
    • Whether the prosecution sufficiently proved that the appellant “sold and delivered” a dangerous drug.
    • Whether there was sufficient proof to establish that the appellant had the requisite knowledge (“scienter”) that the substance was a dangerous drug.
  • Procedural and Evidentiary Issues Raised by the Appellant
    • The error in giving undue weight to the prosecution’s witnesses despite identified discrepancies.
    • The error in convicting the appellant on account of the alleged sale and delivery of the dangerous drug, in light of the absence of clear and consistent evidence.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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