In the case of People of the Philippines v. Ronaldo Bayan, the Supreme Court affirmed the conviction of Ronaldo Bayan for the illegal sale of shabu, a dangerous drug, under Section 5, Article II of Republic Act No. 9165. The Court emphasized that minor inconsistencies in witness testimonies do not necessarily undermine their credibility, and the non-presentation of buy-bust money is not fatal to the prosecution’s case if the sale is adequately proven and the drug itself is presented in court. This ruling underscores the importance of consistent and credible testimony from law enforcement officers and adherence to the chain of custody in drug-related cases to secure a conviction.

Buy-Bust Operation: How Much Detail Matters in Drug Sale Convictions?

The case originated from a buy-bust operation conducted by the Station Drug Enforcement Unit (SDEU) of the Novaliches Police Station, prompted by information that Ronaldo Bayan and Irene Bayan were involved in illegal drug trade. PO2 Emeterio Mendoza, Jr., acting as the poseur-buyer, purchased 0.03 grams of shabu from Ronaldo Bayan in exchange for a 100-peso bill. Following the transaction, PO2 Mendoza identified himself as a police officer and arrested Ronaldo Bayan. Irene Bayan, who attempted to escape, was also arrested, and marijuana leaves were found in her possession.

At trial, Ronaldo Bayan denied the charges, claiming he and Irene were framed by police officers. However, the Regional Trial Court (RTC) gave credence to the testimonies of the buy-bust team members and found Ronaldo guilty of violating Section 5, Article II of Republic Act No. 9165, sentencing him to life imprisonment and a fine of P500,000.00. The Court of Appeals (CA) affirmed Ronaldo’s conviction, while acquitting Irene Bayan of the charges against her. Ronaldo Bayan then appealed his conviction to the Supreme Court, arguing that the prosecution failed to prove his guilt beyond a reasonable doubt due to inconsistencies in the testimonies of the prosecution witnesses and the failure to present the buy-bust money as evidence.

The Supreme Court addressed Ronaldo Bayan’s arguments, stating that minor inconsistencies in witness testimonies do not necessarily discredit their credibility. The Court reiterated the principle that “discrepancies and inconsistencies in the testimonies of witnesses referring to minor details, and not in actuality touching upon the central fact of the crime, do not impair their credibility.” This acknowledgment reflects a pragmatic understanding that human memory is fallible and that immaterial discrepancies do not invalidate the core truthfulness of a witness’s account. Furthermore, the Court emphasized that the presentation of buy-bust money is not indispensable in drug cases. Its absence does not create a void in the prosecution’s evidence, provided that the sale of dangerous drugs is adequately proven and the drug subject of the transaction is presented before the court. Neither law nor jurisprudence mandates the presentation of any money used in the buy-bust operation, as stated in People v. Salak, G.R. No. 181249, 14 March 2011, 645 SCRA 269, 285.

In prosecutions for illegal sale of shabu, the prosecution must sufficiently prove the identity of the buyer and the seller, the object and the consideration, and the delivery of the thing sold and the payment therefor. These elements were established in this case. The prosecution presented the testimony of PO2 Mendoza, the poseur-buyer, who positively identified Ronaldo Bayan as the seller of the shabu. PO2 Mendoza recounted the transaction in detail, stating that he gave the 100-peso bill to Ronaldo Bayan in exchange for the small plastic sachet containing shabu. His testimony was corroborated by PO3 de Guzman, who acted as a back-up operative during the buy-bust operation. The Court, in its decision, quoted PO2 Mendoza’s testimony, highlighting the direct and unequivocal nature of the evidence presented against Ronaldo Bayan.

Q:	What happened after you were tasked as poseur-buyer?
A:	We proceeded to the subject of our operation.
Q:	Where was that?
A:	No. 17 Guyabano Street, Barangay [Capril], Novaliches, Quezon City.
Q:	What time was that, what time did you arrive there?
A:	About 7:40.
COURT:
	7:40 in the evening?
A:	Yes, your Honor.
PROS. ANTERO:
	What happened when you arrived there?
A:	The informant introduced me to Ronaldo Bayan.
Q:	Where did you get contact with the subject?
A:	At No. 17 Guyabano Street.
Q:	How were you introduced to the subject by the informant?
A:	I was introduced as buyer of shabu.
Q:	To whom?
A:	Ronaldo Bayan, sir.
Q:	Is this Ronaldo Bayan inside this courtroom?
A:	Yes, sir.
Q:	Can you point to him?
INTERPRETER:
	The witness is going to a man in yellow shirt who answered by the name of?
ACCUSED:
	RONALDO BAYAN.
INTERPRETER:
	RONALDO BAYAN.
COURT:
	Who were present when you were introduced by the informant to Ronaldo Bayan?
A:	The live-in partner, Irene Bayan, me, the informant and Ronaldo Bayan, your Honor.
PROS. ANTERO:
	Is this Irene Bayan inside this courtroom?
A:	Yes, sir.
Q:	Can you point to her?
INTERPRETER:
	The witness is [pointing] to a woman who answered by the name of?
ACCUSED 2:
	IRENE BAYAN.
INTERPRETER:
	Irene Bayan.
PROS. ANTERO:
	What happened after you were introduced to Ronaldo Bayan by the informant?
A:	I gave the P100.00, sir.
A:	Ronaldo Bayan, sir.
Q:	You gave it to whom?
A:	To Ronaldo Bayan, sir.
Q:	What did this Ronaldo Bayan do after you handed him this P100.00?
A:	He gave me shabu, sir.
COURT:
	Where was it contained?
A:	Small plastic sachet, your Honor.
PROS. ANTERO:
	He gave you a small plastic sachet?
A:	Yes, sir.
Q:	What happened after he gave you a small plastic sachet?
A:	I introduced myself as policeman.
Q:	What happened after you introduced yourself as a policeman?
A:	I placed my hand on his shoulder and introduced myself as a policeman and told him of his mistake and of his rights.

The Supreme Court also emphasized the importance of preserving the integrity and evidentiary value of the seized drugs by establishing an unbroken chain of custody. The Court noted that the prosecution was able to sufficiently establish the circumstances showing an unbroken chain of custody over the shabu seized from Ronaldo Bayan. This included the fact that PO2 Mendoza received the transparent plastic sachet containing shabu from Ronaldo Bayan, brought the sachet to the police station where he placed his initials “EM,” and then transported the sachet to the crime laboratory for examination. The laboratory examination, conducted by Police Inspector Abraham Verde Tecson, confirmed the presence of methylamphetamine hydrochloride in the white crystalline substance inside the plastic sachet.

The Court found Ronaldo Bayan’s defense of denial to be weak in light of the positive testimonies of the police officers. The defense of frame-up or denial in drug cases requires strong and convincing evidence because of the presumption that the law enforcement agencies acted in the regular performance of their official duties. Bare denials are insufficient to overcome the positive testimonies of credible witnesses. Moreover, there was no evidence of any improper motive on the part of the police officers who conducted the buy-bust operation to falsely testify against Ronaldo Bayan.

The Supreme Court affirmed the lower courts’ factual findings, noting that trial courts are in the best position to evaluate the credibility of witnesses. The Court stated that the evaluation of the credibility of witnesses and their testimonies are best undertaken by the trial court because of its unique opportunity to observe the witnesses’ deportment, demeanor, conduct and attitude under grilling examination. The Supreme Court found no cogent reason to reverse the lower courts’ decisions. As a result, the Court affirmed the decision of the Court of Appeals, which upheld Ronaldo Bayan’s conviction for violation of Section 5, Article II of Republic Act No. 9165, sentencing him to life imprisonment and a fine of P500,000.00. This decision reinforces the stringent penalties associated with drug-related offenses in the Philippines and the Court’s commitment to upholding convictions based on credible evidence and adherence to legal procedures.

FAQs

The Supreme Court’s decision in People v. Ronaldo Bayan serves as a reminder of the strict enforcement of drug laws in the Philippines and the importance of credible evidence and adherence to legal procedures in drug-related prosecutions. The ruling also emphasizes the need for law enforcement agencies to maintain a clear and unbroken chain of custody to ensure the integrity of drug evidence and prevent any doubts about its authenticity.

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: People v. Bayan, G.R. No. 200987, August 20, 2014