PEOPLE OF THE PHILIPPINES, vs. DON RODRIGUEZA.
- G.R. Number: G.R. No. 95902
- Promulgated: 1992-02-04
- Ponente: Regalado, J.
Doctrine
When evidence contains material inconsistencies and the prosecution fails to establish its cause, the presumption of innocence must prevail and conviction cannot stand.
The prosecution must rely on the strength of its own evidence and not on the weakness of the defense; unrefuted allegations of misconduct by arresting officers undermine prosecution credibility.
Facts
Appellant Don Rodrigueza was convicted by the RTC, Legaspi City, Branch 10, for violating Section 4, Article II of RA No. 6425 (Dangerous Drugs Act) and sentenced to life imprisonment and a P20,000 fine.
The Solicitor General recommended acquittal in a Manifestation for Acquittal filed with the Court, prompting the Court to review the testimonial and documentary evidence.
Evidence included a Joint Affidavit of Arrest and testimony from co-accused Segovia indicating Rodrigueza was not among those arrested on 1 July 1987.
Rebuttal witnesses claimed Sgt. Molinawe demanded P10,000 from relatives in exchange for the accused's liberty; this allegation was unrefuted by the prosecution.
Issues
Whether the prosecution established guilt beyond reasonable doubt to sustain appellant's conviction for unlawful drugs possession under RA No. 6425.
Whether the prosecution's witnesses and evidence were sufficiently credible and unimpeached to overcome the presumption of innocence.
Ruling
The Court approved the Solicitor General's recommendation and reversed and set aside the conviction; Rodrigueza is acquitted and ordered released unless otherwise lawfully detained.
The Court found the prosecution failed to overcome the presumption of innocence and relied on inconsistent and unconvincing evidence rather than the strength of its case.
Keywords
G.R. No. 95902, Dangerous Drugs Act of 1972, Republic Act No. 6425, as amended, life imprisonment, P20,000.00 fine, Manifestation for Acquittal, buy-bust operation, marijuana leaves, ultraviolet powder, warrant of arrest, search warrant, custodial investigation, constitutional rights, sworn statement, guilty beyond reasonable doubt, in flagrante delicto, entrapment, poseur buyer, acquittal, appellant