Case Summary (G.R. No. 68997)
Applicable Law
The applicable law in this case is Republic Act No. 6425, also known as the Dangerous Drugs Act of 1972, as amended. It outlines the legal definitions and penalties concerning dangerous drugs, including marijuana.
Charges and Sentencing
Roberto Libag was found guilty by the Regional Trial Court for violating Section 4, Article II of Republic Act No. 6425, resulting in a sentence of life imprisonment, a fine of P20,000, and costs. Libag appealed the decision, seeking reversal of the trial court's verdict based on several arguments detailing alleged errors in the trial.
Grounds for Appeal
Libag's appeal articulated several key grounds:
- Hearsay Testimony: The trial court disregarded what Libag claimed was inherently hearsay testimony from the two arresting officers, arguing that the alleged "buyer" of the marijuana was not presented as a witness.
- Instigation by Police: He contended that the police, through their informer, instigated the commission of the offense.
- Failure to Include All Persons: Libag argued that the prosecution violated procedural rules by not including all responsible parties in the information filed.
- Incredibility of Evidence: He highlighted what he deemed material contradictions in the prosecution's evidence and that the officers’ testimonies were not credible.
- Lack of Knowledge: Lastly, Libag argued he lacked knowledge that the bag he delivered contained marijuana.
Events Leading to Conviction
The trial court found a substantial basis for conviction based on testimonies from the arresting officers detailing a police operation intended to execute a buy-bust involving marijuana. They stated that the accused delivered a bag containing marijuana flowering tops to a police informer during an operation, which established a prima facie case of guilt against Libag despite his defense.
Testimonies and Counterarguments
The testimonies from both the prosecution and defense presented contrasting narratives. The prosecution claimed the successful delivery of marijuana was corroborated by the officers' observations of the arrest. Conversely, Libag argued that he was an unwitting participant, having been approached and paid to deliver what he believed was a harmless package containing vegetables.
Evaluation of Evidence
The trial court found that while the prosecution's evidence did not sufficiently prove a case of illegal sale of marijuana, there was enough proof of delivery. Notably, there were discrepancies regarding the identity of the poseur-buyer. The failure to present this individual as a witness raised significant concerns regarding the credibility and completeness of the prosecution's case.
Legal Reasoning and Conclusion
The appellate court scrutinized the prosecution’s failure to prove essential elements of the charge beyond a reasonable doubt. The
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Background of the Case
- Accused: Roberto Libag y Cabading
- Charge: Violation of Section 4, Article II of Republic Act No. 6425 (Dangerous Drugs Act of 1972 as amended).
- Original Sentence: Imprisonment for life, a fine of P20,000.00, and costs.
- Date of Incident: November 7, 1983.
- Location: Baguio City, Philippines.
- Court: Regional Trial Court, First Judicial Region, Branch V, Baguio City.
Proceedings and Grounds for Appeal
- Libag appealed the trial court's decision, asserting various grounds for his acquittal, including:
- Disregard of hearsay testimony from arresting officers.
- Allegations of police instigation in committing the offense.
- Procedural violations during preliminary investigation.
- Conviction based on unreliable evidence and contradictions in witness testimonies.
- Lack of evidence proving his knowledge of the marijuana's presence in the bag.
Prosecution's Case
- Evidence Presented:
- Testimonies from Cpl. Eduardo Garcia and Pfc. Virgilio Visperas, members of the Vice and Narcotics Division.
- An informer reported a marijuana sale, leading to a buy-bust operation.
- The informer arranged a deal to buy marijuana from the sellers.
- Libag was arrested after delivering a plastic bag to the informer, which contained three kilos of marijuana.
- Chemical analysis confirmed the presence of marijuana in the seized bag.
Defense’s Version
- Accused's Testimony:
- Libag claimed he was appr