G.R. No. 174980 - Aurelio y Reyes vs. People

Inconsistencies in witness testimonies that do not pertain to the elements of the offense are deemed inconsequential and insufficient to overturn a trial court's conviction.
Defenses based on denial and frame-up must be supported by clear and convincing evidence to be credible against the prosecution's positive testimonies.

On October 22, 2002, two Informations were filed against Radito Aurelio y Reyes for violating Sections 5 and 11, Article II of Republic Act No. 9165.
The first Information (Criminal Case No. MC-02-6019-D) alleged that on October 17, 2002, Reyes unlawfully sold shabu to a poseur buyer, PO1 Julius B. Bacero.
The second Information (Criminal Case No. MC-02-6020-D) charged Reyes with illegal possession of shabu, specifically 0.12 grams, without lawful authority.

Police Chief Inspector Bien B. Calag initiated a buy-bust operation after receiving reports of shabu sales in Mandaluyong City.
SPO2 Bacero, designated as the poseur buyer, successfully purchased shabu from Reyes, who was arrested shortly thereafter.
The police recovered marked money and an additional sachet of shabu from Reyes during a lawful search following his arrest.

Reyes denied the allegations, claiming he was watching television at a neighbor's house when he was forcibly taken by police officers.
He alleged that the police attempted to extort money from him and that the drugs were planted.
Two witnesses, his sister and neighbor, corroborated his account, but their testimonies were inconsistent.

On March 2, 2005, the trial court convicted Reyes of both charges, sentencing him to twelve years of imprisonment for each violation and ordering the forfeiture of the seized drugs.

The Court of Appeals affirmed the trial court's decision but modified the penalties, imposing life imprisonment for the sale of shabu and a fine of P500,000, while maintaining the twelve-year sentence for possession.

Reyes contended that both the trial and appellate courts erred in believing the prosecution's witnesses and in concluding that a buy-bust operation occurred.

The prosecution must prove the identity of the buyer and seller, the object of the sale, and the delivery of the drug.
For possession, it must be shown that the accused knowingly possessed a prohibited drug without lawful authority.

The testimonies of the prosecution witnesses were found credible and consistent with the evidence presented.
The trial court's assessment of witness credibility is given great weight, especially when affirmed by the appellate court.

The inconsistencies pointed out by Reyes were deemed trivial and did not affect the core elements of the offenses.
Minor discrepancies in witness accounts do not undermine their overall credibility.