Facts:

The case involves the People of the Philippines as the plaintiff-appellee against accused-appellants Danilo D. Rodriguez and Edwin D. Rodriguez. The events transpired on January 22, 1998, in Iloilo City, Philippines. The accused were charged with violating Article II, Section 4, in relation to Article IV, Section 21(b) of Republic Act No. 6425, known as the Dangerous Drugs Act. The charges were formally filed on January 26, 1998, alleging that the accused, with deliberate intent and without any justifiable motive, conspired to sell and distribute one block of dried marijuana fruiting tops weighing 932.3 grams without the necessary permit or authority.

During the arraignment on April 15, 1998, both accused pleaded not guilty, leading to a trial where the prosecution presented three witnesses: P/SINSP Angela Baldevieso, a forensic chemist; PO1 Richard Lambino; and PO1 Wendel Alfonso. The prosecution's case was built on a buy-bust operation initiated after receiving inform...

Facts:

1. Background of the Case

   • Accused-appellants Danilo D. Rodriguez and Edwin D. Rodriguez were charged with violating Article II, Section 4, in relation to Article IV, Section 21(b) of Republic Act No. 6425 (Dangerous Drugs Act). They were accused of selling and distributing 932.3 grams of dried marijuana fruiting tops without authority on January 22, 1998, in Iloilo City.

2. Prosecution's Evidence

   • The prosecution presented three witnesses: P/SINSP Angela Baldevieso (Forensic Chemist), PO1 Richard Lambino (poseur-buyer), and PO1 Wendel Alfonso (back-up operative).
   • On January 13, 1998, a confidential informant reported that accused-appellants were selling marijuana. A buy-bust operation was planned.
   • On January 21, 1998, PO1 Lambino, posing as a buyer, met with accused-appellants and agreed to purchase 1 kilogram of marijuana for P6,000. An initial payment of P1,500 in marked money was given.
   • On January 22, 1998, accused-appellants arrived at the agreed location and delivered a black bag containing 932.3 grams of marijuana. They were arrested after the delivery.

3. Defense's Claims

   • Accused-appellants denied the charges, claiming they were framed. They testified that they were on their way to visit a sick relative when they were forcibly arrested and falsely accused.
   • They alleged that the police planted the marijuana and that they were maltreated during their arrest.

4. Trial Court Decision

   • The Regional Trial Court found accused-appellants guilty beyond reasonable doubt and sentenced them to reclusion perpetua and a fine of P3,000,000 each. The marijuana was ordered forfeited in favor of the government.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Consummation of the Crime

   • Under Article II, Section 4 of R.A. No. 6425, the crime is consummated by the delivery of prohibited drugs, regardless of payment. The prosecution established the identity of the buyer, seller, object, and consideration, as well as the delivery of the marijuana.

2. Presumption of Regularity

   • The testimonies of the police officers enjoy the presumption of regularity in the performance of their duties. The defense failed to present credible evidence to rebut this presumption.

3. Representative Sampling

   • A sample taken from one package is presumed to represent the entire contents unless proven otherwise. The prosecution proved the sample was marijuana, and the defense did not present evidence to contradict this.

4. Frame-Up Defense

   • Frame-up is a common defense in drug cases and is viewed with disfavor unless supported by clear and convincing evidence. The defense's claims were inconsistent and lacked credibility.

5. Appropriate Penalty

   • The penalty of reclusion perpetua is appropriate for the sale and distribution of 932.3 grams of marijuana. However, the fine was reduced to P650,000 based on the accused-appellants' economic condition.

Conclusion:

The Supreme Court affirmed the conviction of accused-appellants Danilo D. Rodriguez and Edwin D. Rodriguez for violating R.A. No. 6425 but modified the fine to P650,000, to be paid solidarily. The decision underscores the importance of credible evidence in drug-related cases and the presumption of regularity in the performance of official duties by law enforcement officers.