Title
People vs. Quinones y Loveria
Case
G.R. No. 250908
Decision Date
Nov 23, 2020
A jail officer found shabu on a minor inmate, who implicated another inmate. The Supreme Court acquitted the accused due to insufficient evidence and unreliable testimony.
reasonable doubt
untrustworthy testimony
minor
A

Case Summary (G.R. No. 220087)

Facts of the Occurrence and Seizure

At about 3:40 p.m. on June 14, 2015, Jail Officer Niel A. Romana conducted a roll call on the second floor of the Camarines Norte Provincial Jail, accosted trustee-inmate Rogelio B. Caparas, and in a bodily search recovered from Caparas’s pocket a small piece of paper sealed with black electrical tape, a small plastic sachet containing a white crystalline substance (weighing 0.0944 gram), and a rolled aluminum foil. Upon opening the taped paper JO Romana observed a handwritten note and the sachet. The officer confiscated the items, reported to his supervisor, and marked the items in the presence of the accused-appellant. The items were inventoried and photographed in the presence of PDEA Agent Enrico Barba, two barangay officials, and a media representative. Laboratory examination returned positive for methamphetamine hydrochloride (“shabu”).

Testimony and Positions of Key Witnesses and the Accused

Caparas testified that the note and the plastic sachet sealed with electrical tape were given to him by accused-appellant, who instructed him to deliver the contents to inmate Frederick Cua. Jail Officer Romana and Warden Pajarillo corroborated the arrest and the proceedings surrounding the seizure. Accused-appellant denied the charge, asserting that at the relevant time he was in his first-floor cell, was later summoned to the Warden’s office where he was accused, refused to sign the inventory because he was not the owner, and maintained he did not leave his cell between approximately 3:30 p.m. and 9:00 p.m.

RTC Judgment and Rationale

The Regional Trial Court, by judgment dated September 4, 2017, found accused-appellant guilty beyond reasonable doubt of Attempted Illegal Sale of Dangerous Drugs, imposed life imprisonment and a P500,000 fine, and credited the prosecution witnesses. The RTC accepted Caparas’s testimony as establishing that the note and sachet originated from accused-appellant and were intended for delivery to Cua. The court noted that, although accused-appellant was not caught in flagrante, testimonial evidence was sufficient to establish the source of the contraband, and because there was no allegation of conspiracy between Caparas and accused-appellant, the acts were to be judged individually.

Court of Appeals Ruling

The Court of Appeals, in a decision dated November 29, 2018, affirmed the RTC conviction. The CA held that the accused’s bare denial could not prevail against the positive testimony of prosecution witnesses that identified him as the source of the shabu intended for delivery/sale to Cua. The appellate court further found that the prosecution established the elements of the offense and that the chain of custody of the seized items had been preserved.

Issue Presented to the Supreme Court

The dispositive issue before the Supreme Court was whether accused-appellant was guilty beyond reasonable doubt of Attempted Illegal Sale of Dangerous Drugs under Section 5 in relation to Section 26 of RA 9165.

Governing Legal Principles on Attempted Illegal Sale

To secure a conviction for Attempted Illegal Sale of Dangerous Drugs the prosecution must prove beyond reasonable doubt: (a) the identities of the buyer and the seller, the object (the dangerous drug), and the consideration; and (b) that the sale was attempted — i.e., the offender commenced the commission of the felony by overt acts but did not complete the act due to some cause other than voluntary desistance. The appeal in a criminal case confers full jurisdiction on the reviewing court to examine and revise the record and correct errors in the appealed judgment. The presumption of innocence guaranteed by the 1987 Constitution requires that the prosecution prove every element and the participation of the accused beyond reasonable doubt.

Supreme Court’s Analysis on Evidence and Identity

The Supreme Court found the appeal meritorious and identified a reasonable doubt concerning the essential element of the identities of buyer and seller. Unlike buy-bust situations where apprehending officers directly identify parties, this case turned entirely on the testimony of Caparas, the person who was actually found in possession of the contraband and who named accused-appellant as the source. The Court observed that Caparas had a clear motive to shift blame to avoid criminal liability, noting it was conspicuous that Caparas himself was not charged with illegal possession despite being found with the drugs. The Court found that the testimonies of JO Romana and Warden Pajarillo did not independen

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