Case Summary (G.R. No. 90391)
Charges and Trial Outcome
Salih Juma was charged under Article II, Section 4 of Republic Act 6425. The trial court decided on September 8, 1987, convicting Juma of selling ten sticks of marijuana cigarettes and sentencing him to life imprisonment while ordering the destruction of the illegal drugs. Juma appealed the decision, contending errors of judgment by the trial court related to the credibility of witnesses and the sufficiency of evidence against him.
Prosecution's Account of Events
The prosecution's narrative, backed by Sgt. Marino Undangan's testimony, detailed a buy-bust operation conducted by the Narcotics Command prior to the arrest. Undangan, acting as a poseur-buyer, approached Juma while he was reportedly selling marijuana. After exchanging P10 for the drugs, the law enforcement team apprehended Juma and two other individuals, recovering additional marijuana and cash. A subsequent laboratory analysis confirmed the seized substances as marijuana.
Defense's Claims
In contrast to the prosecution's assertions, Juma maintained his innocence, claiming he was wrongfully accused. He testified that he was approached and apprehended by unidentified individuals who coerced him into admitting guilt and later confronted him with drugs that were presented as evidence. Juma argued that he had been subjected to physical maltreatment during his detention, impacting his ability to defend himself effectively.
Evaluation of Evidence and Credibility
The appellate court found the prosecution's evidence compelling and credible, dismissing Juma's defense of frame-up and instigation as unsubstantiated. The court emphasized the legal distinction between entrapment, which involves law enforcement capturing a criminal in the act, versus instigation, where an officer coaxes an individual into committing an offense. In this case, the court upheld that the buy-bust operation was lawful and effectively executed, reinforcing the credibility of the officers' testimony.
Legal Principles on Entrapment
The decision discussed the legal principle of entrapment as legally permissible when carried out with proper oversight. It distinguished between entrapment, which allows law enforcement to capture individuals committing offenses, and instigation, which implies coercion into a crime. The appellate court found no evidence of instigation in Juma’s case, as he willingly sold drugs to the poseur-buyer.
Weight of Witness Testimony
Regarding the trial court's evaluation of witness credibility, the appellate court reiterated its respect for the trial court's unique position to assess wit
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Case Overview
- Case Citation: 292-A Phil. 560
- Court: Second Division
- G.R. No.: 90391
- Date of Decision: March 24, 1993
- Parties:
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: Salih Juma y Sampangmaga
- Nature of the Case: Violation of the Dangerous Drugs Act of 1972 (Republic Act 6425)
Charges and Proceedings
- Charge Against the Accused:
- The accused was charged with selling ten (10) sticks of marijuana cigarettes without lawful authority on October 28, 1988, in Zamboanga City.
- Trial Court Decision:
- The trial court found Salih Juma guilty beyond reasonable doubt.
- Sentenced to life imprisonment and a fine of P20,000.00.
- Ordered the destruction and burning of the marijuana cigarettes seized.
Appeal and Alleged Errors
- Errors Assigned by the Accused-Appellant:
- The trial court allegedly erred in:
- Giving full credence to the prosecution witnesses.
- Asserting that the appellant's testimony was inconsistent and evasive.
- Concluding that the prosecution's evidence established guilt beyond reasonable doubt.
- The trial court allegedly erred in:
Summary of the Prosecution’s Evidence
- Prosecution's Version of Events:
- On October 28, 1988, a buy-bust operation was conducted by Sergeant Eulolio Reguina and his team against the accused.
- Sgt. Marino Undangan posed as a buyer, purchasing marijuana sticks from the accused at his residence.
- Following the purchase, the accused was arrested, and marijuana was recovered from him and others present.
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