TL;DR

The Supreme Court affirmed the conviction of James Atad for selling marijuana, even though the poseur-buyer (the person who pretended to buy drugs from Atad) testified that Atad did not sell him any drugs. The Court emphasized that the testimony of law enforcement officers is presumed credible, especially when there is no evidence of ill motive, and the poseur-buyer’s testimony was inconsistent. This ruling highlights that a conviction can be sustained based on the arresting officer’s testimony, even if a key witness recants, particularly when the recanting witness lacks credibility. The decision also underscores the importance of assessing witness credibility in drug-related cases.

When the Buyer Says ‘No Sale’: Assessing Witness Credibility in Buy-Bust Operations

The case of People of the Philippines vs. James Atad revolves around a critical question: Can a drug conviction stand when the prosecution’s own poseur-buyer denies the sale? In this instance, James Atad was convicted of violating the Dangerous Drugs Act based primarily on the testimony of the arresting officer, SPO4 Renato Salazar. However, the person who allegedly bought the marijuana, Arnesto Geronggay, testified that Atad did not sell him the drugs. This contradiction raised significant doubts about the veracity of the prosecution’s case.

At trial, the prosecution presented evidence that Salazar witnessed Atad selling marijuana to Geronggay during a buy-bust operation. The defense countered by presenting Geronggay, who claimed he bought marijuana from someone else and that Atad was mistakenly arrested. The trial court, however, found Salazar’s testimony more credible, citing the lack of motive to falsely accuse Atad and the inconsistencies in Geronggay’s statements. The central issue then became one of credibility: Whose version of events should the court believe?

The Supreme Court upheld the trial court’s decision, placing significant weight on the credibility of the police officer. The Court stated that credence is accorded to the testimonies of prosecution witnesses who are law enforcers, and they are presumed to have regularly performed their duty in the absence of convincing proof to the contrary. This presumption of regularity is a crucial aspect of Philippine jurisprudence, often giving the prosecution a significant advantage in drug cases.

The Court also scrutinized the testimony of the poseur-buyer, Arnesto Geronggay, finding it riddled with inconsistencies and contradictions. Geronggay’s statements regarding the timing of the alleged drug purchase, his presence at the scene, and his interactions with the police were all inconsistent and illogical. Due to these inconsistencies, the court dismissed his testimony as unreliable, highlighting that testimonial evidence must be credible, reasonable, and in accord with human experience to be believed.

Furthermore, the Court emphasized that findings of trial courts on the credibility of witnesses deserve a high degree of respect. Having observed the demeanor of witnesses during the trial, the lower court was in a better position to determine the issue of credibility. Absent any clear showing that the trial court overlooked or misapplied facts, its findings will generally not be disturbed on appeal. Building on this principle, the Supreme Court found no reason to overturn the lower court’s assessment of Geronggay’s credibility.

Despite the inadmissibility of a receipt seized from Atad due to violations of his constitutional rights during custodial investigation, the Court held that sufficient evidence existed to prove the illegal sale of marijuana. Salazar’s direct testimony of witnessing the transaction, coupled with the forensic chemist’s confirmation that the seized items were indeed marijuana, provided enough evidence to sustain the conviction. The Court, however, reduced the penalty imposed due to amendments in the Dangerous Drugs Act, aligning the sentence with the quantity of marijuana involved and applying the Indeterminate Sentence Law.

For inquiries regarding the application of this ruling to specific circumstances, please contact Atty. Gabriel Ablola through gaboogle.com or via email at connect@gaboogle.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 of the Philippines vs. James Atad, G.R. No. 114105, January 16, 1997