G.R. No. 56098 - People vs. Villamil y Ferdez

The People of the Philippines filed Criminal Case No. 87-54417 against Juan de la Cruz y Gonzales and Reynaldo Beltran y Aniban for violation of Section 4, Art. II in relation to Section 21, Art. IV of R.A. No. 6425 (Dangerous Drugs Act), alleging the sale/delivery of three aluminum foil wrappers containing marijuana on May 4, 1987 in Manila.
The accused pleaded not guilty on May 26, 1987 and trial commenced on August 18, 1987.

A confidential informant (“Arnel”) tipped off the 13th Narcotics Regional Unit. Under Team Leader T/Sgt. Jaime Raposas, P/Pfc. Adolfo Arcoy acted as poseur-buyer, accompanied by Arnel, to purchase P10.00 worth of marijuana.
At about 2:30 PM on May 4, 1987 at Maliclic St., Tondo, Manila, Arcoy negotiated with Juan de la Cruz, who instructed Beltran to deliver one foil of marijuana. Arcoy signaled by scratching his head, prompting the team to converge, identify themselves, and arrest both accused.
On Juan de la Cruz’s person were found the P10.00 marked bill (Exh. C-1) and three aluminum foils of marijuana (Exhs. B-2′ to B-4′).

Juan de la Cruz claimed he was ill and bedridden at home on the date, never left nor received visitors, and denied involvement in drug transactions. He alleged the agents conducted a warrantless, unauthorized raid, ransacking his premises and effecting bodily search.
Reynaldo Beltran asserted he was arrested earlier that afternoon at a billiard hall on mere identification by the same informant, then brought to a parked vehicle and to NARCOM headquarters before learning of the charges.

The trial court compared the conflicting versions, found the prosecution witnesses credible, and, on March 15, 1988, convicted both accused beyond reasonable doubt of illegal sale/delivery of marijuana under R.A. No. 6425.
Each was sentenced to reclusion perpetua, a P20,000 fine, accessory penalties, and forfeiture of the marijuana exhibits; the marked bill was to be returned.

Appellant Juan de la Cruz died on February 21, 1989; his case was dismissed. The appeal continued only as to Reynaldo Beltran.
Beltran assigned errors challenging the constitutionality of the buy-bust, admissibility/authenticity of evidence (drugs, marked money, receipts), absence of civilian witnesses, credibility of defense witnesses, and alleged police motives to fabricate evidence.

Is the buy-bust operation under R.A. No. 6425 unconstitutional, rendering evidence inadmissible?
Does the absence of a civilian or neutral witness to the seizure of drugs vitiate the prosecution’s case?
Should the post-scene receipt (Exhibit E) be excluded for lack of the original draft?
Must the marked money be positively identified in court to prove sale?
Did the trial court err in rejecting the testimony of defense witnesses Lolita Mendoza and Maribeth Manapat?
Were there sufficient grounds to infer corrupt motives by police to fabricate evidence?
Does non-presentation of the civilian informer undermine the prosecution’s case?