In Lapuz v. People, the Supreme Court affirmed that a conviction for the sale of illegal drugs can stand even when based primarily on the testimony of a single witness, particularly a police poseur-buyer. This ruling underscores that the testimony of a law enforcement officer, presumed to have acted regularly in the performance of their duties, is sufficient if it establishes the key elements of the sale, such as the identity of the buyer and seller, the object of the transaction, and the exchange of consideration.

The Case of the Unremembered Serial Numbers: Can a Drug Conviction Stand?

The case arose from a buy-bust operation conducted by the Northern Police District Command in Valenzuela City. Following a tip about an individual named “Erning” selling illegal drugs, the police organized a sting operation. PO3 Cesar J. Pineda acted as the poseur-buyer, purchasing two sachets of shabu from Rufino Lapuz using marked money. Lapuz was arrested, and the seized drugs were presented as evidence. At trial, Lapuz challenged his conviction, arguing that the prosecution’s case rested solely on PO3 Pineda’s testimony and that the failure to produce the logbook with the serial numbers of the marked money undermined the evidence against him. The Court of Appeals upheld the trial court’s decision, leading to this appeal to the Supreme Court.

The Supreme Court, in resolving the issues raised by Lapuz, reiterated several key principles in Philippine jurisprudence regarding drug-related offenses and the admissibility of evidence. First, the Court affirmed that a conviction can be sustained based on the testimony of a single, credible witness. This principle is particularly applicable when the witness is a law enforcement officer who is presumed to have performed their duties regularly. The Court emphasized that to overturn this presumption, there must be clear and convincing evidence that the officer either failed to properly perform their duty or was driven by an improper motive.

Building on this principle, the Court addressed Lapuz’s argument that PO3 Pineda’s inability to recall the serial numbers of the marked money cast doubt on his credibility. The Court found this argument unpersuasive, stating that it would be unreasonable to expect a witness to remember such details, especially given the passage of time and the complex nature of serial numbers. Instead, the Court suggested that PO3 Pineda’s partial memory could even be seen as a sign of honesty, as a truthful witness is not always expected to provide a perfectly precise account.

The Court also addressed Lapuz’s contention that the prosecution’s failure to present the logbook containing the serial numbers constituted a willful suppression of evidence. Here, the Court clarified that the logbook would have merely served as corroborative evidence. The presentation of the marked money itself, identified by PO3 Pineda as the bills he used to purchase the drugs, was deemed sufficient. In fact, the Court cited previous rulings stating that the presentation of marked money is not even essential, as long as the sale is adequately proven through other evidence.

The Court also emphasized that the elements necessary for conviction in cases involving illegal drugs are (1) the identity of the buyer and seller, object and consideration; and (2) the delivery of the thing sold and the payment thereof. As long as these are established, the absence of any other form of evidence would not automatically lead to acquittal.

What is material is proof that the transaction or sale actually took place, coupled with the presentation in court of the substance seized as evidence.

In light of these considerations, the Supreme Court found no reason to overturn the lower courts’ rulings. The Court emphasized that trial courts are in the best position to assess the credibility of witnesses, and their findings should not be disturbed unless there are significant facts that were overlooked. Finding no such errors, the Court concluded that the prosecution had proven Lapuz’s guilt beyond a reasonable doubt.

FAQs

What was the key issue in this case?	The key issue was whether the testimony of a single poseur-buyer, without corroborating evidence like serial numbers of marked money, is sufficient to convict someone for selling illegal drugs.
Can a person be convicted of selling drugs based on a single witness’s testimony?	Yes, a conviction can be sustained based on the testimony of a single credible witness, especially if that witness is a police officer presumed to have acted regularly.
Is it necessary for the police to present the marked money in court?	No, the presentation of the marked money is not always essential, as long as the sale is adequately proven through other evidence, like the poseur-buyer’s testimony.
What if the police cannot recall the serial numbers of the marked money?	The inability to recall the serial numbers of the marked money does not automatically discredit the police officer’s testimony. The Court might consider such failure as minor or insignificant especially in light of other evidence presented.
Does the prosecution have to present a logbook with the serial numbers of the marked money?	The logbook serves as corroborative evidence and is not indispensable if the sale can be proven through other evidence and a credible witness.
What elements must be proven to convict someone of selling illegal drugs?	The prosecution must prove the identity of the buyer and seller, the object of the sale (the illegal drug), the consideration (the money paid), and the delivery of the drug to the buyer.
What is the presumption of regularity in the performance of official duty?	This presumption means that law enforcement officers are presumed to have acted in accordance with the law and their duties unless there is clear evidence to the contrary.
What kind of evidence can overturn the presumption of regularity?	Clear and convincing evidence that the officer failed to properly perform their duty or was driven by an improper motive, or compelling contradictory evidence.

The Lapuz case illustrates the importance of credible witness testimony in drug-related prosecutions, particularly when law enforcement officers are involved. It clarifies that minor inconsistencies in testimony, such as the inability to recall specific serial numbers, do not automatically invalidate a conviction. The case continues to impact law enforcement and judicial procedure regarding drug-related crimes in the Philippines, underscoring the balance between individual rights and public safety.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Rufino Lapuz v. People, G.R. No. 150050, June 17, 2004