G.R. No. 83810 ; January 28, 1991
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. REY BERNARDINO y MOLINA, accused-appellant.

FACTS

Acting on an informant’s tip, a police team proceeded to Malaya St., Marikina, to conduct a buy-bust operation against Rey Bernardino, who was allegedly selling marijuana. Patrolman Roberto Jocson, using a marked ten-peso bill, approached Bernardino and asked to “score.” Bernardino left and returned with three sticks of marijuana, which he gave to Jocson in exchange for the marked money. Upon Jocson’s pre-arranged signal, the other officers arrested Bernardino. A search yielded the marked bill and a wallet containing marijuana residue. Forensic analysis confirmed the substances were marijuana, leading to Bernardino’s prosecution for selling prohibited drugs.
At trial, the prosecution presented the testimonies of the arresting officers and the forensic chemist. Bernardino, as the sole defense witness, denied the charge, claiming he was digging a septic pit at the time of his arrest. The Regional Trial Court convicted him of violating the Dangerous Drugs Act, sentencing him to life imprisonment and a fine. On appeal, Bernardino challenged the credibility of the prosecution witnesses, citing alleged inconsistencies in their testimonies, and argued that his guilt was not proven beyond reasonable doubt.

ISSUE

Was the guilt of the accused-appellant for the illegal sale of marijuana proven beyond reasonable doubt?

RULING

Yes, the Supreme Court affirmed the conviction. The Court held that the alleged inconsistencies in the testimonies of the police officers—pertaining to minor details such as the initiation of the operation or who frisked the accused—were inconsequential and did not undermine the core narrative of the buy-bust operation. Such minor variances are expected from different witnesses recounting the same event and do not signify dishonesty as long as there is fundamental agreement on the principal facts. The Court noted that any initial misstatements by some officers regarding who was the buyer were promptly clarified and corrected on record.
The Court further dismissed the defense’s speculative argument that a drug pusher would not sell to a stranger, observing that drug transactions have become increasingly casual. The illegal sale was conclusively established through the direct testimony of the poseur-buyer, the presentation of the marked money and the marijuana sticks, and the positive forensic report. While the Court disregarded an inadmissible verbal admission obtained without proper warnings, it ruled that the remaining evidence overwhelmingly supported the conviction. The decision of the trial court was affirmed in its entirety.