G.R. No. 87429 - People vs. Bati

On July 27, 1986, at around 5:30 p.m., a civilian informer notified the police of an impending transaction involving marijuana at the Dona Crispina Park Subdivision in Barangay Bagong Bayan, San Pablo City.
Patrolmen Jose Luciano, Angelito Caraan, Nelson Dimatulac, and Democrito Cuenca were dispatched to the vicinity of the transaction immediately after receiving the information.
The officers strategically divided their tasks:

Cuenca and Dimatulac were sent to the Bolante Section of the public market near the railroad tracks.
Luciano and Caraan, riding in a police jeepney, proceeded directly to the designated area.

Upon arriving at the scene, Luciano and Caraan observed two individuals—appellant Regalado Bati and Warner Marquez—standing on a street corner approximately forty to fifty meters away.
The police witnessed an exchange where Marquez was seen receiving an object from Bati; subsequently, Bati placed the item into his pocket while Marquez inserted it into his pants.
After the transaction, Marquez was followed by the officers when he fled on a bicycle; they caught up with him along a circular street toward the national highway.
During questioning, Marquez initially denied receiving anything but eventually produced a wrapped object. When unwrapped, it turned out to be a pink plastic bag containing marijuana.
Marquez admitted that he had purchased marijuana from Bati for P190.00 and was immediately arrested on the spot.

Following Marquez’s arrest, Luciano and Caraan pursued Bati, who was later apprehended at the Bolante section of the area.
Bati admitted to selling the marijuana to Marquez, and he too was arrested; the P190.00 received from the transaction was confiscated.
Both arrested individuals were brought to the police station, where they confirmed involvement in the sale and distribution of marijuana.
The confiscated money and marijuana were processed as evidence:

Patrolman Luciano affixed his initials to the peso bills before they were turned over to Sgt. Bayani Yte, Chief of the Intelligence and Investigation Section of the San Pablo City Police Station.
The marijuana—contained in a pink plastic bag and wrapped in newspaper—was examined by a Forensic Chemist (P/Lt. Rosalinda Royales) at the PC Crime Laboratory, which confirmed the substance tested positive for marijuana.

An Information was subsequently filed in the Regional Trial Court, Fourth Judicial Region, Branch 30, San Pablo City under Criminal Case No. 4760-SP.
The charge brought against Regalado Bati involved the violation of Section 4, Article II of Republic Act No. 6425 (as amended), specifically for unlawfully selling and distributing marijuana without legal authorization.
At trial, although Bati pleaded not guilty and offered an alibi claiming he was on his way to buy vegetables for his mother, his explanation was unconvincing.
The trial court found Bati’s defense inadequate, noting that:

His testimony failed to support his claim of engaging in regular vegetable marketing.
The cumulative testimonies of the police officers and other witnesses overwhelmingly indicated his involvement in the drug transaction.

Bati was convincingly identified as the principal actor in the illegal transaction by the prosecution’s witnesses.
The trial court, after considering all evidence and testimonies, rendered a judgment convicting Bati for the offense.
The court sentenced him to suffer life imprisonment, imposed a fine of P25,000.00 (with subsidiary imprisonment in case of insolvency), and canceled his bail bond due to a prior violation of bail conditions.

Whether the arrest of Regalado Bati without a warrant, as well as the seizure of the money and marijuana, violated his constitutional right to be secure in his person and property.
Consideration of the exceptions provided under Section 5, Rule 113 of the Rules in Criminal Procedure, specifically the arrest made in the presence of the offender and the search incidental to a valid arrest.

Whether the non-presentation of the alleged buyer (Warner Marquez) and the civilian informer amounted to suppression of evidence which, if testified, might have affected the prosecution’s case.
The impact of such non-presentation on the cumulative evidentiary value of the case.

Whether the alleged inconsistencies in the testimonies of law enforcement officers and the forensic chemist regarding the handling and identification of the marijuana specimen could discredit the prosecution’s evidence.
The effect of these alleged discrepancies on establishing the identity of the substance as marijuana.

Whether the trial court erred in imposing a penalty that allowed for subsidiary imprisonment in the event of insolvency despite the rule against subsidiary imprisonment when the penalty imposed is higher than prision correccional.