Case Digest (G.R. No. L-66907)
Facts:
The People of the Philippines v. Normita Sadie y Castro, G.R. No. 66907, April 14, 1987, Supreme Court First Division, Narvasa, J., writing for the Court. The appellant, Normita Sadie y Castro, was charged under Section 4, Article II of Republic Act No. 6425 (the Dangerous Drugs Act of 1972, as amended) with trafficking in dangerous drugs after a CANU (Constabulary Anti-Narcotics Unit) buy-bust operation on January 24, 1983; the Regional Trial Court (RTC) of Pasay City (Criminal Case No. 83-4217-P) convicted her and sentenced her to life imprisonment and a P20,000 fine.According to the prosecution, an informer known only as “Boyet” reported a marijuana pusher called “Norma” on Felix Street, Pasay City. CANU operatives allegedly prepared marked money (xerox reproductions and recorded serial numbers) — a twenty-peso and a ten-peso bill — and sent Boyet to purchase marijuana. Around 6:20 p.m. the operatives observed the suspect exit her house, hand a plastic bag to Boyet, and then signaled to arrest her. Patrolwoman Josie Abueg purportedly found the marked bills in the right pocket of the appellant’s duster; a receipt for seized items was issued by Sgt. Buena Carreon and signed by the appellant in the presence of a barangay official. Laboratory analysis identified the plastic bag’s contents as marijuana fruiting tops.
The appellant denied the prosecution’s narrative. She testified she had taken her sick child to a clinic earlier that day, borrowed P50 (two twenties and a ten) from a sister‑in‑law, and returned home to find men who entered her residence and forcibly took her, apparently mistaking her for another woman. She claimed she never sold marijuana, that the bills were the money she had borrowed (kept under her child’s pillow), and that she signed the receipt only after assurance from the barangay chairman that it merely stated no personal property was taken. The barangay chairman testified she had no reputation for drug dealing.
The RTC convicted. The appellant appealed to the Supreme Court. The People’s case rested largely on the CANU operatives’ testimony and exhibits (the marked bills, the xerox reproduction, and the seized plastic bag). The Supreme Court reviewed the testimonial and physical evidence and noted material inconsistencies among prosecution witnesses (number of poseur-buyers, number of agents present), tensions between exhibits (the alleged pre-marked xerox copy bore a date/time of arrest), and a discrepancy between witnesses’ des...(Subscriber-Only)
Issues:
- Was the appellant proven guilty beyond reasonable doubt of trafficking in dangerous drugs under Section 4, Article II of RA 6425?
- Did the inconsistencies and defects in the prosecution’s testimonial and physical evidence justify overturning the trial court’s factual findings and acquitting the appellant despite the usual...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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