Case Summary (G.R. No. 78527)
Facts of the Case
On November 4, 1985, a confidential informant alerted NARCOM about a notorious drug pusher named Johnny from Baguio City, who was in Manila seeking a buyer for marijuana. M/Sgt. Arsenio Carlos of NARCOM was tasked with conducting an intelligence operation and agreed to pose as the buyer. During an arranged meeting at the Uniwide Sales Center in Cubao, Quezon City, M/Sgt. Carlos expressed his interest in purchasing three kilograms of marijuana, establishing a plan for a subsequent transaction.
On November 9, 1985, M/Sgt. Carlos and a backup team arrived at the prearranged location. When Johnny arrived with a traveling bag containing marijuana, M/Sgt. Carlos confirmed the contents and signaled the backup team to arrest him. A receipt for the sequestered items was prepared and signed by both parties involved. The marijuana was sent for laboratory examination, confirming its identity.
Defense Argument
John Guiagui admitted to being arrested on November 9, 1985, but denied ownership of the bag and its contents. His defense claimed that he was in the restaurant for recreational purposes and that the arrest was unwarranted. Guiagui argued that NARCOM agents had assaulted him and coerced a confession, casting doubt on the legality of his arrest and the evidence presented against him.
Prosecution's Case
The prosecution's case rested on the testimony of NARCOM officers M/Sgt. Carlos and P/Lt. Casimiro Llanes, who provided consistent details about the operation and the accused's participation. They asserted that the operation was a lawful entrapment rather than instigation, wherein the accused was already involved in drug trade activities.
Legal Analysis of Entrapment vs. Instigation
The court highlighted the legal distinction between entrapment and instigation. Entrapment involves law enforcement’s efforts to catch a defendant in the act of a crime, while instigation entails the law enforcement actively persuading or inducing a person to commit an offense they would not have otherwise committed. In this case, the court found that entrapment was evident since the accused was already engaged in illegal drug transactions prior to NARCOM's involvement.
Court's Ruling
The court concluded that the conviction should be upheld because Guiagui had not successfully demonstrated that he was in
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Case Background
- The case involves an appeal by John Guiagui y Koteng against the judgment rendered by the Regional Trial Court of Quezon City in Criminal Case No. Q-42795.
- Guiagui was found guilty of violating Section 4, Article II of Republic Act No. 6425, as amended, which pertains to the illegal sale of narcotics, specifically marijuana.
- The trial court sentenced him to life imprisonment and imposed a fine of P30,000.00, along with costs.
Incident Details
- On November 4, 1985, the PC Narcotics Command (NARCOM) received information from a confidential informant about a notorious drug pusher named Johnny who was in search of a buyer for marijuana in Quezon City.
- M/Sgt. Arsenio Carlos was assigned to conduct an intelligence operation and agreed to pose as a buyer.
- Carlos met Johnny at the Uniwide Sales Center, where they negotiated the sale of three kilos of marijuana at P1,500.00 per kilo. Johnny promised to return the following Saturday, November 9, 1985, with the marijuana.
Arrest and Evidence Collection
- On November 9, 1985, M/Sgt. Carlos and his backup team arrived at the Uniwide Sales Center to await Johnny's arrival.
- Johnny appeared carrying a traveling bag, which he confirmed contained the marijuana.
- Carlos opened the bag and, upon confirming the presence of marijuana, signaled his backup team, leading to Johnny's arrest.
- A receipt for the bag and its contents was prepared and signed by both M/Sgt. Carlos and John Guiagui.