Case Summary (G.R. No. 117174)
Applicable Law
The case revolves around the violation of Section 4, Article II of Republic Act No. 6425, as amended, more commonly known as the Dangerous Drugs Act of 1972.
Overview of Proceedings
The Regional Trial Court found Eric Timtiman guilty of selling prohibited drugs, specifically marijuana, and sentenced him to life imprisonment and a fine of P20,000. The conviction stemmed from an incident on September 5, 1990, in Tanay, Rizal, where Timtiman allegedly sold two tea bags of marijuana and three marijuana cigarettes.
Prosecution's Evidence
The prosecution's case was primarily built on the testimonies of law enforcement officers involved in a buy-bust operation. P/Lt. Julita T. De Villa performed chemical examinations that confirmed the presence of marijuana in the seized items. Sgt. Norberto Macaraeg, acting as a poseur-buyer, testified that he purchased the items from Timtiman, after which he announced the arrest. Another officer, CIC Nonato Esquilon, corroborated Macaraeg's account, stating he witnessed Macaraeg apprehending Timtiman.
Defense's Evidence
Timtiman's defense presented multiple witnesses, including Renato Concepcion and Angelita San Juan, who testified that he was not engaged in drug dealing but was present at the restaurant to discuss personal matters. The defense argued that Timtiman was mistaken for someone involved in illicit activity and clarified that there was a lack of corroborative evidence linking him to the crime, especially concerning the absence of the marked money.
Appellant's Assignments of Error
Timtiman's appeal identified several errors committed by the trial court:
- Conviction based on inadequate identification solely based on physical description.
- Conviction despite unclear and contradictory prosecution testimonies.
- Conviction rooted in an illegal arrest.
- Conviction amidst significant doubts about the events surrounding his arrest.
- Failure to present substantial corroborative evidence.
Court's Analysis
Upon review, the appellate court noted significant inconsistencies and contradictions between the testimonies of the prosecution witnesses, particularly between Macaraeg and Esquilon. The testimony from the defense witnesses was seen as equally plausible, thereby triggering reasonable doubt regarding Timtiman's guilt. The court emphasized that the burden of proving guilt beyo
...continue readingCase Syllabus (G.R. No. 117174)
Case Overview
- Court: Supreme Court of the Philippines
- Date of Decision: November 04, 1992
- G.R. No.: 101663
- Parties: People of the Philippines (Plaintiff) vs. Eric F. Timtiman (Accused)
- Original Decision: Conviction of Eric Timtiman for the sale of marijuana, sentenced to life imprisonment and a fine of P20,000.
Background of the Case
- The accused, Eric Timtiman, was charged with violating Section 4, Article II of Republic Act 6425, amended, due to the alleged sale and delivery of marijuana.
- The incident occurred on September 5, 1990, in Tanay, Rizal, where Timtiman allegedly sold two tea bags of marijuana and three sticks of marijuana cigarettes to an undercover police officer.
Prosecution Evidence
- Witnesses:
- P/LT. Julita T. De Villa: Forensic Chemist who confirmed the substances as marijuana through lab tests. The evidence presented included two bags of marijuana leaves and three marijuana cigarettes, all weighing a total of 2.53 grams.
- Sgt. Norberto Macaraeg: Identified as the poseur-buyer during the buy-bust operation. He testified that he approached Timtiman, purchased the marijuana, and subsequently arrested him with the help of his partner.
- CIC Nonato Esquilon: Provided corroborating testimony about the surveillance and arrest but noted he did not see Timtiman with the marijuana before the arrest.
Defense Evidence
- Defendant's Testimony: Eric Timtiman claimed he was wrongly identified and was at the restaurant to discuss elopement plans with his uncle and girlfriend. He denied selling