G.R. No. 100985 - People vs. Aranda y Doria

Case Summary (G.R. No. 100985)

Charges and Joint Trial

In the information for Criminal Case No. C-35532, the prosecution alleged that, “on or about” August 17, 1990, appellant, “without authority of law,” “wilfully, unlawfully and feloniously” sold and delivered to Villanueva two small white transparent plastic bags containing methamphetamine hydrochloride, knowing the same to be such. On motion of the public prosecutor, Criminal Cases No. C-35532 and No. C-35533 were tried jointly. Appellant pleaded “not guilty” on September 3, 1990. Villanueva changed his plea from “not guilty” to “guilty,” after which he was sentenced to imprisonment of six years and one day and to pay a fine of P6,000.00, plus costs.

Factual Version for the Prosecution

The trial court found the prosecution’s version to be as follows. At about 5:00 p.m. on August 17, 1990, Pfc. Alexander Corpuz of the Anti-Narcotics Unit of the Kalookan City Police Station received a phone call from an informant. The informant reported that a tricycle driver with Plate No. NM-4831 was about to go to the corner of Gen. Tinio and Reparo Streets, Bagong Barrio, Kalookan City, to buy shabu from appellant, identified as “Teresita Aranda.” Acting on this report, Lt. Eliseo de Leon formed a team to verify the information, with Corpuz as team leader and Pfc. Elmario Adelante and Pat. Romeo Sengco as members. The team positioned itself near Reparo and Gen. Tinio Streets.

The policemen allegedly observed the tricycle (Plate No. NM-4831) arrive and stop near the vicinity, after which appellant emerged from the compound at Suntan Street and approached the tricycle while carrying a shoulder bag. The policemen claimed that appellant, alone, handed what appeared to be small plastic bags to the tricycle driver, later identified as Benito Villanueva. Shortly before boarding, appellant allegedly delivered the plastic bags to Villanueva, and then, upon a hand signal from Corpuz, the policemen approached the suspects. Pfc. Adelante allegedly seized Villanueva’s hand when he saw the driver about to throw away the plastic bags, and two transparent bags containing suspected methamphetamine hydrochloride were recovered. Pat. Sengco allegedly requested appellant to open her closed right hand, and one small transparent plastic bag containing suspected methamphetamine hydrochloride was reportedly found.

After the arrest, the suspects were brought to the Kalookan City Police Station for investigation.

Appellant’s Defense

Appellant denied that she sold or delivered any drugs. She claimed that she was a resident of No. 70 San Juan, Pasay City and that, on the date in question, she went to the house of a friend named Melissa in Bagong Barrio, Kalookan City. When she could not see Melissa, she allegedly took a tricycle along Reparo Street on her way back to Pasay City. Appellant asserted that policemen suddenly appeared, arrested the tricycle driver later identified as Villanueva, and then forced her to alight and likewise arrested her. She emphasized that, at the time of her arrest, there was allegedly no warrant and that she was not informed why she was brought to police headquarters. She further stated that she was working at a Capiz Factory and that, while at headquarters, she was separated from Villanueva and the officer specifically Corpuz was allegedly asking for money from her, but she said she had none.

Trial Court Judgment

On June 13, 1991, the trial court rendered judgment finding appellant guilty beyond reasonable doubt for delivering methamphetamine hydrochloride or “shabu.” It sentenced appellant to life imprisonment, imposed a fine of P20,000.00, ordered costs, and directed the forfeiture of the two small transparent plastic bags in favor of the Government, for disposition by the Dangerous Drugs Board. The court also credited preventive imprisonment in accordance with Art. 29 of the Revised Penal Code, as amended.

Issues Raised on Appeal

Appellant assigned errors that broadly challenged (a) the credibility of the prosecution witnesses, particularly the apprehending officers, by pointing to purported discrepancies; (b) the insufficiency of evidence to establish any sale or delivery of prohibited drugs; and (c) the trial court’s refusal to credit the defense evidence presented.

Discrepancies in Prosecution Witnesses

On review, the Court held that there were “notable inconsistencies” among the testimonies of the three apprehending officers: Pfc. Alexander Corpuz, Pfc. Elmario Adelante, and Pat. Romeo Sengco. The Court specifically pointed out discrepancies on material points, including who investigated the case after the arrest and who received the informant’s report.

First, as to who investigated appellant, Corpuz and Sengco pointed to Pat. Romeo Baldonado, but Adelante testified that it was Pfc. Florante Santos who investigated the case. Baldonado allegedly disclaimed that he was the investigator. The Court noted that no explanation was offered for the failure of the policemen to identify the investigator they claimed had investigated and prepared the joint-affidavit they signed.

Second, as to who received the information from the informant, Corpuz testified that he relayed the report to P/Lt. Eliseo de Leon, while Adelante and Sengco testified that P/Lt. Eliseo de Leon received the information from the informant.

Third, there were conflicting statements about markings and masking tape on the plastic bags allegedly delivered by appellant, as well as conflicting testimony from Corpuz regarding whether he was inside the jeep at the time of the arrest and when he claimed he approached the area after Adelante’s shout.

Additionally, the trial court itself noted a discrepancy concerning the existence and handling of a rag allegedly associated with appellant’s delivery and the movement of this item. It observed that Corpuz and Sengco did not mention any rag (Exhibit “J”) placed by appellant inside a packet and passed to Villanueva, while Adelante mentioned the rag and even brought it to the courtroom, explaining that he forgot to deliver it to the investigator and kept it until trial.

The Court concluded that these inconsistencies “shook the foundation” of the prosecution’s case by engendering serious doubt as to the credibility of the prosecution witnesses, referencing People v. Hilario, 196 SCRA 716 (1991).

The Court’s “Telling Blow”: Villanueva’s Testimony

The Court treated as decisive the testimony of Benito Villanueva, who was presented as a prosecution witness to identify the person who delivered the drugs to him. The Court observed that Villanueva did not name appellant when asked to identify the person who delivered the drugs. The prosecution also did not show that Villanueva had been declared a hostile witness as required by Section 12, Rule 132 of the Rules of Court, which permits impeachment only after an appropriate court declaration upon adequate showing of adverse interest, unjustified reluctance, or misleading the party into calling the witness.

The Court reasoned that, absent proof that Villanueva had an adverse interest in the case, or that he was unjustifiably reluctant, or that he misled the prosecution, Villanueva could not be considered hostile. Consequently, the prosecution was bound by his testimony that nothing was delivered to him by appellant.

The Court quoted Villanueva’s material testimony in which he stated that nothing was delivered to him (“Wala naman siyang idiniliber sa akin”) and that the methamphetamine was just given to him by a tricycle passenger whom he did not know. The Court underscored that this testimony directly negated the prosecution theory that appellant sold and delivered the dangerous drugs to Villanueva.

Elements of the Offense and Failure of Proof

The Court reiterated

Case Syllabus (G.R. No. 100985)

Parties and Procedural Posture

People of the Philippines prosecuted Teresita Aranda y Doria for violating Section 15, Article III of the Dangerous Drugs Act (R.A. No. 6425 as amended).
The RTC Branch 124, Kalookan City convicted appellant and imposed life imprisonment and a fine of P20,000.00, with forfeiture of the drug exhibits.
Appellant appealed from the judgment, assigning multiple alleged errors on credibility and sufficiency of evidence.
The records also involved Benito Villanueva as a co-accused in a separate case (Criminal Case No. C-35533) for violating Section 16, Article III of the Dangerous Drugs Act.
On motion of the public prosecutor, Criminal Case No. C-35532 and Criminal Case No. C-35533 were tried jointly.
Benito Villanueva changed his plea to guilty, while appellant pleaded not guilty.

Key Factual Allegations

The information alleged that on or about August 17, 1990, in Kalookan City, appellant, without authority of law, wilfully, unlawfully and feloniously sold and delivered to Benito Villanueva two small white transparent plastic bags containing Methamphetamine Hydrochloride (“shabu”), a regulated drug, knowing it to be such.
The prosecution’s narrative placed the buy-and-delivery within a police surveillance operation beginning after a phone call to Pfc. Alexander Corpuz of the Anti-Narcotics Unit.
The informant allegedly described a tricycle with Plate No. NM-4831 to go to a specified area to buy shabu from appellant.
Police officers formed a team to verify the report and positioned themselves near the designated corner.
The police claimed appellant emerged from a compound and approached the tricycle while carrying a shoulder bag.
The police testified that immediately before boarding, appellant allegedly handed what appeared to be small plastic bags to the tricycle driver, identified as Benito Villanueva.
The officers then allegedly approached, recovered plastic bags containing suspected methamphetamine hydrochloride, and brought the suspects to the police station.

Defense Version Presented

Appellant denied participation in any drug transaction and claimed she was merely traveling to her residence after visiting a friend who had just given birth.
Appellant stated that policemen arrested the tricycle driver first, then forced her to alight from the tricycle and likewise arrested her.
Appellant asserted that at the time of arrest there was no warrant and that she was not informed why she was brought to the police headquarters.
Appellant claimed she was separated from Villanueva at the police headquarters and alleged that the officer Corpuz was asking for money from her.
Appellant maintained that she could not provide any money at that time.

Evidence and Apprehending Officers’ Testimony

The Court observed that the prosecution’s case depended on testimonies of three apprehending officers: Pfc. Alexander Corpuz, Pfc. Elmario Adelante, and Pat. Romeo Sengco.
The Court found notable inconsistencies among the officers’ accounts.
As to who investigated and prepared a joint affidavit, Pfc. Corpuz and Pat. Sengco pointed to Pat. Romeo Baldonado, while Pfc. Adelante stated that it was Pfc. Florante Santos who investigated the case.
Pat. Baldonado disclaimed that he was the investigator, and the Court found it questionable why the officers did not identify the correct investigator and explain the discrepancies.
As to who received the information from the informant, Pfc. Corpuz testified he relayed the information to P/Lt. Eliseo de Leon, while Pfc. Adelante and Pat. Sengco testified that P/Lt. Eliseo de Leon received the information directly from the informant.
As to the presence of markings and masking tape on the confiscated transparent plastic bags, Pfc. Adelante gave conflicting answers in cross-examination regarding when masking tape and markings were present and when they were marked.
The Court also noted internal con