2 People V Guinto

G.R. No.
198314 September 24, 2014

PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee, vs. RICHARD GUINTO Y SAN ANDRES, Accused-Appellant.
Recit-Ready Case Summary:
● The RTC and CA Found Guinto guilty beyond reasonable doubt of Sxection 5, Article II of RA No. 9165 for the
Illegal Sale of Dangerous Drugs.
● Guinto appealed, assailing the inconsistent statements of the apprehending police officers with respect to the
circumstances of his illegal arrest and the broken chain of custody which would warrant his acquittal.
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General Rule of Law/Doctrine: Use this incase maam ask why did the Supreme Court override the facts when the
Supreme court are not the trier of facts
Supreme Court is not a trier of facts and as a general rule it defers to the appreciation and evaluation of the evidence
by the lower court
In People v. Roble, the Court ruled that generally, the evaluation of the trial court of the credibility of the witnesses and
their testimonies is entitled to great weight and generally not disturbed upon appeal. However, such rule does not apply
when the trial court has overlooked, misapprehended, or misapplied any fact of weight or substance. In this present case,
the contradictions, numerous and material, warrant the acquittal of accused-appellant.
One of the means used by the Court in determining the credibility of the prosecution witnesses is the objective test.
Following this test, in order to establish the credibility of prosecution witnesses regarding the conduct of buy-bust
operation, prosecution must be able to present a complete picture detailing the buy-bust operation—from the initial
contact between the poseur-buyer and the pusher, the offer to purchase, the promise or payment of the consideration,
until the consummation of the sale by the delivery of the illegal subject of sale. The manner by which the initial contact
was made, the offer to purchase the drug, the payment of the buy bust money, and the delivery of the illegal drug must be
the subject of strict scrutiny by courts to insure that law-abiding citizens are not unlawfully induced to commit an offense.
FACTS: (facts in here only presented the inconsistencies if you wanna read it)
The prosecution presented PO1 Familara as its second witness to corroborate the statements given by PO1 Mendoza.
However, several inconsistencies were apparent in his testimony.
When asked during his direct examination on who gave the buy-bust money to PO1 Mendoza, PO1 Familara answered
that it was SPO3 Matias. Likewise, the pre-arranged signal was differently described as scratching of the nape instead of
raising of hand. He also testified that their asset arrived at around one o’clock in the morning to accompany them to
Pinagbuhatan. Another inconsistency which surfaced was when PO1 Familara testified that upon the consummation of
illegal sale, he went to the place of the arrest and saw PO1 Mendoza arresting Guinto. PO1 Mendoza then positively
identified Guinto as the one who sold one (1) plastic sachet of illegal drug instead of two (2) sachets.
Finally, the last witness presented by the prosecution was Police Officer 2 Richard Noble (PO2 Noble). He corroborated
the statements given by his fellow police officers but again, presented an inconsistency as to the time of the asset’s arrival
compared to the one narrated by PO1 Familara. A conflict came out as to the time of the team’s arrival to the target area
and as to how long they waited for the accused to go out. In his direct, he testified that the asset arrived at the police
station before eleven o’clock in the evening prior to the buy-bust operation. Afterwards, they had a briefing on the
operation. He recalled that they waited for around 15 to 20 minutes before the accused came out while PO1 Mendoza
testified that they waited for the accused for two hours. When asked again by the Court on the time of their arrival, he
answered that it was at around one o’clock in the morning.
ISSUE: Whether the the presumption of regularity of the performance of duties of the Police officers should prevail
HELD: The court ruled in the negative
TURBY
In People v. Unisa this Court held that "in cases involving violations of the Dangerous Drug Act, credence is given to
prosecution witnesses who are police officers for they are presumed to have performed their duties in a regular manner,
unless there is evidence to the contrary suggesting ill-motive on the part of the police officers."
True, the absence of ill motive or ill will is ordinarily considered by this Court as proof that the statements of the police
officers is credible. As maintained by the People, through the Office of the Solicitor General, in the absence of any
improper motive, presumption of regularity of performance of duty prevails. However, it must be similarly noted that the
presumption of regularity in the performance of duty of public officers does not outweigh another recognized presumption
- the presumption of innocence of the accused until proven beyond reasonable doubt.
Although, in several occasions, the Court had declared that the presumption of regularity of performance of duties must
be harmonized with the other interest of the State which is the interest of adherence to the presumption of innocence of
the accused.
However in case of conflict between the presumption of regularity of police officers and the presumption of innocence of
the accused, the latter must prevail as the law imposes upon the prosecution the highest degree of proof of evidence to
sustain conviction.
In conclusion, the court ruled that this case exemplifies the doctrine that conviction must stand on the strength of the
Prosecution’s evidence, not on the weakness of the defense.
Evidence proving the guilt of the accused must always be beyond reasonable doubt. If the evidence of guilt falls short of
this requirement, the Court will not allow the accused to be deprived of his liberty. His acquittal should come as a matter of
course.
The present case shows that the prosecution fell short in proving with certainty the culpability of the accused and
engendered a doubt on the true circumstances of the buy-bust operation. In dubio pro reo. When moral certainty as to
culpability hangs in the balance, acquittal on reasonable doubt inevitably becomes a matter of right.
TURBY

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G.R. No.

198314 September 24, 2014

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HELD: The court ruled in the negative

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