Title
People vs. Ramos, Jr. y Yabut
Case
G.R. No. 88301
Decision Date
Oct 28, 1991
A civilian informant reported marijuana sales at a restaurant, leading to a buy-bust operation. Ramos was arrested after selling marijuana to an undercover officer. The court upheld his conviction, modifying the penalty to life imprisonment, citing credible prosecution evidence and the legitimacy of the operation. Ramos' defense claims were dismissed due to lack of corroboration.
drug peddlers
arresting officers
testimonies
A

Case Digest (G.R. No. 88301)

Facts:

People of the Philippines v. Benjamin Ramos, Jr., y Yabut, G.R. No. 88301, October 28, 1991, First Division, Medialdea, J., writing for the Court. The case arises from a criminal information filed in the Regional Trial Court, Third Judicial Region, Branch 29, Cabanatuan City, charging Benjamin Ramos, Jr. with violation of the Dangerous Drugs Act (RA 6425, Art. II, Sec. 4) for allegedly selling 2.5 grams of marijuana on May 17, 1986.

According to the prosecution, a civilian informant notified Narcotics Command (NARCOM) officers of a marijuana peddler at the “Hang Out” restaurant. Capt. Maximo Dilla organized a buy‑bust team. Sgt. Danilo Maulon acted as poseur‑buyer with a marked P10.00 bill; after Ramos allegedly delivered a plastic teabag containing marijuana to Sgt. Maulon and received the marked bill, officers arrested Ramos and brought him to the NARCOM office. The teabag was submitted to the Philippine Constabulary Crime Laboratory and Forensic Analyst Capt. Marlene Salangad testified it tested positive for marijuana.

At trial Ramos denied the buy‑bust, alleging the drugs were planted and that he was arrested following a quarrel with the restaurant owner, Dr. Melvin Garcia. The defense did not present Dr. Garcia or several other persons whom Ramos named; it instead offered testimony (Samuel Ancheta) about a purportedly recovered stereo unit. The trial court (Judge Tirso Y. Reyes presiding) found the prosecution witnesses credible and convicted Ramos on March 3, 1989, sentencing him to “reclusion perpetua or life imprisonment” and a P20,000 fine.

Ramos appealed the conviction. Before the Supreme Court, the Solicitor General restated the prosecution’s buy‑bust account and evidence (marked bill, witnesses, laboratory report), while Ramos maintained the defense theory of planted evidence and irregular arrest. The S...(Subscriber-Only)

Issues:

  • Was the conviction for sale of a prohibited drug under Section 4 of R.A. 6425 proper given the circumstances of the buy‑bust operation and the evidence presented?
  • Was the trial court’s imposition of “reclusion perpetua or life imprisonment” a correct application of the penalt...(Subscriber-Only)

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)
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