PEOPLE OF THE PHILIPPINES, vs. CARLOS Y ARELLANO.
- G.R. Number: G.R. No. 110357
- Promulgated: 1994-08-17
- Ponente: Davide, Jr., J.
Doctrine
When credibility of witnesses is at issue, appellate courts generally will not disturb trial court findings because the trial court is in a better position to assess witness deportment and testimony, unless the trial court plainly overlooked material facts.
The Indeterminate Sentence Law may be applied to determine the penalty range for the offense charged, here producing a range from six months arresto mayor to six years prision correccional.
Facts
An information was filed on 10 May 1991 in the RTC of Makati charging Carlos Tranca y Arellano with violating Section 15, Article III of R.A. No. 6425 (Dangerous Drugs Act) for allegedly selling methamphetamine hydrochloride (shabu) on or about 07 May 1991 in Makati (place within court's jurisdiction).
The trial court heard witnesses and made credibility findings which the appellate court found no reason to disturb, applying the settled rule that trial courts are best positioned to assess witness credibility.
The Court applied the Indeterminate Sentence Law in assessing punishment for the offense.
The challenged decision of Branch 136, RTC Makati in Criminal Case No. 2754 was affirmed, subject to a modification of the penalty.
Issues
Whether the conviction by the RTC should be disturbed on appeal given the trial court's credibility findings.
Whether the Indeterminate Sentence Law should be applied and what the proper penalty range is.
Ruling
The Court affirmed the RTC's decision (Conviction upheld) but modified the penalty; under the Indeterminate Sentence Law the accused is sentenced to an indeterminate penalty from six (6) months arresto mayor (minimum) to six (6) years prision correccional (maximum). Costs against the accused.
Keywords
G.R. No. 110357, Dangerous Drugs Act of 1972, R.A. No. 6425, as amended, Section 15, Article III of R.A. No. 6425, willfully, unlawfully and feloniously sell, deliver and distribute Methamphetamine Hydrochloride (shabu), regulated drug, Criminal Case No. 2574, buy-bust team, poseur-buyer, marked money, fluorescent powder, Physical Identification Report No. PI-073-91, methamphetamine hydrochloride (shabu), chemical examination, thin-layer chromatograhic examination, infrared spectrometric record analysis, Initial Chemistry Report No. D-464-91, (Final) Chemistry Report No. D-464-91, allegations against him, framed by the police officers