Case Digest (G.R. No. 102880)
Facts:
People of the Philippines v. Raul Cruz y Lalaw, G.R. No. 102880, April 25, 1994, Supreme Court Second Division, Regalado, J., writing for the Court.On July 29, 1991 an information was filed in the Regional Trial Court (RTC) of Valenzuela, Branch 172, charging Raul Cruz with violation of Section 4, Article II of Republic Act No. 6425 (Dangerous Drugs Act of 1972) for allegedly selling several sticks of marijuana cigarettes and dried marijuana leaves with flowering tops. On August 2, 1991 Cruz pleaded not guilty. After trial, the RTC, in a decision dated November 8, 1991, found him guilty and sentenced him to life imprisonment and a fine of P20,000, with credit for preventive detention.
The prosecution’s case rested largely on the testimony of Pat. Cesar J. Pineda of the Anti‑Narcotics Unit, who narrated a June 23, 1991 buy‑bust operation on Sanchez Street, Arkong Bato, Valenzuela. Pineda testified that he acted as the poseur‑buyer using a marked P20.00 bill (serial logged), met Cruz (alias “Dalaw”), handed him the marked money, and then received six sticks of marijuana; a subsequent search allegedly yielded three more sticks and a plastic bag of dried marijuana leaves with flowering tops that were later submitted to the NBI. NBI forensic chemist Demelen Renton de la Cruz testified the submitted items tested positive for marijuana.
Cruz denied the charges, claiming he was a sampaguita vendor apprehended by Pineda, a barangay tanod (“Sonny”) and another man; he said the police frisked him, found nothing, forced him to go to his house, and later presented an item wrapped in plastic which he denied owning. Cruz denied selling drugs and disputed the circumstances of recovery.
On appeal to the Court before the Supreme Court, the pivotal question became the credibility of Pat. Pineda, whose sworn preliminary statement and trial testimony contained material inconsistencies (e.g., whether the six sticks were handed over immediately or after Cruz went into an alley; whether police proceeded to Cruz’s house to recover the flowering tops; differing accounts of where the additional three sticks were found — garter of underwear vs. back pocket; and inconsistent descriptions of the seized plant material — “dried marijuana leaves” vs. “flowering tops”). The p...(Subscriber-Only)
Issues:
- Was the evidence adduced by the prosecution sufficient to prove beyond reasonable doubt that Raul Cruz committed the offense charged under Section 4, Article II of RA 6425?
- Did the contradictions between Pat. Pineda’s sworn statement and his trial testimony, and other attendant circumstances, justify rejecting his testim...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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