Case Summary (G.R. No. 188708)
Charge and Trial Outcome
Samuel Salamanes was charged along with Bolasa and Cabamban for selling, delivering, and transporting marijuana—specifically, marijuana flowering tops—contrary to Section 4 of Republic Act No. 6425, as amended by subsequent laws. Following trial, the lower court acquitted Bolasa and Cabamban due to insufficient evidence, while convicting Salamanes and imposing a penalty of life imprisonment and a fine of P 20,000.00.
Facts Surrounding the Buy-Bust Operation
On May 17, 1985, a civilian informer reported drug activity to the police, prompting a buy-bust operation. With marked money provided by the police, the informer engaged with Cabamban, Bolasa, and Salamanes at the basketball court. Evidence showed Salamanes received the money from Bolasa and subsequently handed marijuana to the informer, which triggered the police’s intervention. Although the police did not recover marijuana during an immediate search of the suspects, the marked money was found in Salamanes’ possession, and the marijuana was later identified through laboratory testing.
Defense and Testimonies
The defense presented an alternative narrative, asserting that Salamanes and his co-defendants were wrongfully arrested as suspected drug addicts. Testimonies from Bolasa and Cabamban echoed this claim, with Salamanes insisting that police officers coerced him during detention to admit guilt regarding the marijuana. The trial court's evaluation of these testimonies revealed inconsistencies and a lack of corroborating evidence, undermining the defense's credibility.
Errors Alleged by the Appellant
In his appeal, Salamanes claimed several errors by the trial court: wrongful conviction based on insufficient evidence, misplaced reliance on police testimonies, and the absence of the civilian informer as a witness, which he deemed essential for a fair trial. He further argued that his exoneration should follow given the reasonable doubt surrounding his alleged guilt.
Court’s Response to Allegations
The appellate court addressed the credibility of witnesses, emphasizing that trial judges are best positioned to evaluate the reliability of testimonies presented. It upheld that the prosecution's evidence sufficiently established Salamanes' involvement in the drug transaction through the testimonies of the arresting officers, which were consistent and corroborated by the circumstances of the buy-bust operation. The court found that the non-presentation of the informer did not undermine the prosecution’s case, given the discretion allowed to prosecuting officers regarding witness selection.
Findings on the Defense of Extortion
Salamanes’ defense centered on allegations of extortion by arresting police officers, suggesting they fabricated charges against him and improperly solicited money for his release. However, the court noted the absence of any
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Case Background
- Samuel Salamanes, Isagani Bolasa, and Gerardo Cabamban were charged with selling, delivering, and transporting marijuana flowering tops, a prohibited drug.
- The trial court acquitted Bolasa and Cabamban due to insufficient evidence but found Salamanes guilty under Section 4 of Republic Act 6425, sentencing him to life imprisonment and a fine of P20,000.00.
Incident Details
- On 17 May 1985, a civilian informer reported to the Valenzuela Police Station about a drug sale occurring at a local basketball court.
- Following the report, a buy-bust operation was initiated by the police, involving Sgt. Teodoro Sandro, Pat. Eduardo B. Puchero, and Pat. Alfredo Gadiano, along with the informer.
- A marked P50.00 bill, noted with the initials "EBP," was given to the informer to purchase marijuana and signal the police upon completion of the transaction.
Buy-Bust Operation
- The civilian informer approached Cabamban and was later joined by Bolasa and Salamanes.
- The marked money was passed from Cabamban to Bolasa and finally to Salamanes, who subsequently handed over the marijuana to the informer.
- Upon the pre-arranged signal, police apprehended all three suspects, although two attempted to flee.
- A body search revealed no marijuana but the marked money was found on Salamanes.
Evidence Collection and Analysis
- The civilian informer surrendered the marijuana, which was pa