Facts:

The case centers around Renato Mendoza Javier y Torres, who was convicted by the Regional Trial Court of Makati, Branch 133, for violating Article II, Section 4 of Republic Act No. 6425, known as the Dangerous Drugs Act of 1972. On September 11, 1985, during a buy-bust operation conducted by the Narcotics Command (NARCOM), initiated by a tip-off about marijuana selling in Pulang-Lupa, Las Pinas, persons led by Lt. Leonardo Lavares executed the operation. The operation involved Lt. Lavares, Sgt. Aladano as the poseur-buyer, Barangay Captain De La Cruz as the informant, and other team members. The team provided the poseur-buyer with marked money, previously dusted with ultraviolet powder, to purchase marijuana.

At around 4:45 PM, Sgt. Aladano approached the accused, who was introduced to him by his cousin, Barangay Captain De La Cruz. The appellant sold two aluminum foils containing marijuana, and upon receiving the payment, he attempted to flee but was apprehended by the NARCOM o

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Facts:

Incident and Charge

• Defendant-appellant Renato Mendoza Javier y Torres was charged with violating Article II, Section 4 of Republic Act No. 6425 (Dangerous Drugs Act of 1972, as amended).
• The charges stemmed from an alleged buy-bust operation conducted on September 11, 1985 in Las Pinas, Metro Manila.
• The information stated that the accused was involved in wilfully, unlawfully, and feloniously selling and/or delivering dried marijuana fruiting tops, a prohibited drug.

Prosecution’s Account of the Buy-Bust Operation

• At around 3:00 p.m. on September 11, 1985, the Narcotics Command Unit (NARCOM) of the Philippine Constabulary in Camp Crame received a tip-off that an individual (referred to as “Ray”) was selling marijuana to out-of-school youth.
• Lt. Manuel Raval, NARCOM Commanding Officer, ordered Lt. Leonardo Lavares to lead a team for a buy-bust operation with a designated buyer-poseur, Sgt. Aladano, along with other officers.
• Upon arriving at Tramo, Pulang-Lupa, Las Pinas, the team executed the operation by:
• Providing Sgt. Aladano with marked 5-peso bills dusted with ultra-violet powder to be used as purchase money.
• Locating the accused around 4:45 p.m., wherein Sgt. Aladano initiated contact under the introduction of Barangay Captain De La Cruz, who was also related to the appellant.
• Conducting a simulated drug purchase: Sgt. Aladano exchanged money for a package, which he later opened to find two small packages containing marijuana.
• Preventing the accused from escaping by seizing him immediately and detaining him along with the seized contraband.
• Evidence was later processed at the PC-INP and PC Crime Laboratories:
• Lt. Tita Advincula’s forensic examination confirmed the presence of marijuana.
• Reports from Engr. Isidra de Guzman noted the presence of bright yellow ultra-violet fluorescent powder on the hands, arms, and face of the accused, and on the money bills used in the transaction.

Defendant-Appellant’s Version of Events

• The accused asserted that on September 11, 1985, while having a snack near his residence, he was suddenly accosted by men claiming to be NARCOM agents.
• He explained that:
• His arrest came after a group of men, including a man identified as Lt. Lavares, apprehended him and later planted marijuana leaves in his pocket.
• Another officer, identified as Pat. Antonio, demanded money from him for his release, a demand which he alleges constitutes extortion.
• While in custody, he was taken to Camp Crame where:
• During an interrogation session in a room containing a cigarette pack wrapped with marijuana leaves, he was forced to sign a document that he contends was done under duress.
• He was physically maltreated, including an incident where a NARCOM agent kicked him while he was using the comfort room and was prevented from washing off a powder that was reportedly rubbed on his hands.
• The appellant maintained his innocence by claiming that he was solely a victim of an incriminatory setup by law enforcement.

Trial Proceedings

• At the arraignment, the accused pleaded not guilty.
• The prosecution called several witnesses, including:
• Lt. Lavares (team leader).
• Sgt. Aladano (buyer-poseur).
• Forensic experts (Lt. Tita Advincula and Engr. Isidra de Guzman) who provided laboratory findings.
• The defense presented the accused himself, his mother, and later his father to support a claim of being framed and subjected to extortion.
• On cross-examination, discrepancies emerged regarding:
• The timeline of events, with conflicting reports between Lt. Lavares and Sgt. Aladano.
• The feasibility of conducting the operation within a two-hour period without prior surveillance.
• The alleged involvement of Barangay Captain De La Cruz as a middleman in the drug transactions.
• Despite these differences, the trial court found the prosecution’s evidence sufficient to establish guilt beyond reasonable doubt.

Credibility and Evidentiary Findings

• The trial court assessed the credibility of all witnesses, particularly emphasizing:
• The consistent testimony of law enforcement agents who were performing their official duties.
• The corroborative evidence provided by forensic reports that confirmed the presence of marijuana and fluorescent powder on the accused.
• Inconsistencies cited by the defense were determined to be minor and insufficient to undermine the overall credibility of the prosecution’s testimony.
• The extortion claim was not substantiated by convincing evidence during the trial.

Issue:

Whether the cumulative evidence on record is sufficient to establish the guilt of the defendant beyond reasonable doubt.

• Determination of whether the degree of proof required in criminal cases has been met.
• Whether the alleged inconsistencies in the testimonies of the prosecution witnesses are material enough to affect their credibility.

Whether the defense’s claims of framing and extortion by law enforcement agents have any merit.

• Examination of the credibility of the defendant-appellant’s account versus the established facts from the prosecution.
• Evaluation of whether the apparent irregularities in the operation’s timeline and procedures justify a reversal of the conviction.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)