G.R. No. 202761 - MRM Asset Holdings 2, Inc. vs. Standard Chartered Bank

The accused, Eric Timtiman, was charged with violating Section 4, Article II of Republic Act No. 6425 (the Dangerous Drugs Act, as amended) for allegedly selling, delivering, and giving away marijuana.
The offense occurred on September 5, 1990, in Tanay, Rizal, where two tea bags of dried marijuana leaves (totaling 2.53 grams) and three sticks of marijuana cigarettes were allegedly transacted.

Forensic Chemist Lt. Julita T. De Villa performed microscopic, chemical, and thin-layer chromatography tests on the seized items, which were submitted in two exhibits labeled “A” (marijuana leaves) and “B” (marijuana cigarettes).
The laboratory findings in Certificates “B-2” and Chemistry Report No. D-972-90 (“C”) confirmed a positive test for marijuana.

Sgt. Norberto Macaraeg testified that on the day of the operation, he and his companion, CIC Nonato Esquillon, conducted surveillance at the Midway Restaurant in Tanay, Rizal.
Acting as a poseur-buyer, Macaraeg approached the accused based on a description of a tall, muscular, and well-built individual, convincing him to participate in a marijuana sale.
Upon receiving the alleged two cellophane bags and three sticks of marijuana cigarettes and tendering the payment (three ten-peso bills), Macaraeg announced the arrest of the accused.
CIC Nonato Esquillon corroborated, though with a differing sequence of events, stating he saw Macaraeg coming from the comfort room and then observed Macaraeg directing someone with “baka iyon, kasama iyon” before arresting the appellant.

The physical items seized included two plastic bags containing marijuana leaves and three sticks of marijuana cigarettes.
Notably, the three ten-peso bills exchanged in the transaction were not presented as tangible evidence at trial, though their transfer was documented in testimony.

Eric Timtiman testified that he was present in the restaurant to seek advice regarding his plan to elope with Angelita San Juan, a cabaret dancer, and was accompanied by his uncle Renato Concepcion.
According to his version, upon their arrival at around 11:30 a.m., Timtiman and his companions were engaged in conversation when two individuals, mistaken about his identity, apprehended him.
The apprehension occurred amid a commotion in the restaurant, where witnesses noted a person emerging from the comfort room and gesturing, which led to his arrest.

Renato Concepcion testified that while dining, a commotion arose when a man from the comfort room, after a brief exchange, spoke up and signaled for someone to arrest Timtiman.
Angelita San Juan also recounted that a similar scenario unfolded involving a person coming out from the comfort room who prompted the arrest.
Both defense witnesses’ accounts introduced an alternative explanation that conflicted with the sole narrative of the prosecution based on Macaraeg’s testimony.

The Regional Trial Court of Morong, Rizal, Branch 79, found Timtiman guilty beyond reasonable doubt and sentenced him to life imprisonment plus a fine of P20,000.00.
The appellant raised several assignments of error, focusing on:

The incorrect assumption that Timtiman was the only person fitting the physical description.
Inconsistencies and vagueness in the testimonies of the police witnesses, which failed to remove reasonable doubt.
The alleged illegality and irregularities in his arrest.
The lack of corroborative evidence, notably the missing three ten-peso bills which would have otherwise indicated a transactional relationship.

Whether the trial court erred in convicting Timtiman solely on the basis of the assumption that he was the only person present who matched the description provided.

The credibility issue of a witness identifying a “tall, muscular, well-built” individual was scrutinized to determine if the identification was exclusive and reliable.

Whether the accused’s conviction was supported by evidence beyond a reasonable doubt given the conflicting and inconsistent testimonies of the prosecution witnesses.

The divergence between Sgt. Macaraeg’s account and that of CIC Nonato Esquillon, when compared with the defense witnesses’ statements, raised a critical issue on the sufficiency of the evidence.

Whether the trial court committed error in convicting the appellant despite the vagueness and uncertainty of the prosecution’s witnesses and the absence of crucial corroborative evidence (e.g., the non-presentation of the three ten-peso bills).

The missing material evidence was pivotal in proving the transactional nature of the alleged sale.

Whether the manner of Timtiman’s arrest, as presented by both parties, affected the determination of his guilt.

The legality and procedural propriety of the arrest were questioned in relation to the established presumption of innocence.