1. People v.

Boco
On the non-presentation of marked money
DOCTRINE: The testimony of a confidential informant is not necessary because by  The SC reiterated the rule that the non-presentation of the marked money
the nature of their work and for their protection as well, their identities cannot be does not create a hiatus in the evidence of the prosecution, so long as the
revealed publicly. The prevailing doctrine is that their testimonies are not essential sale of the dangerous drugs is adequately proven and that the drug itself
for conviction, nor are they indispensable to a successful prosecution. With the was presented before the court.
testimonies of the arresting officers, they would be, after all, merely corroborative
and cumulative. On the identification of the confiscated shabu
 The Court held that the drugs confiscated from the Petitioners were
sufficiently identified and offered as evidence. In fact, the counsel of the
Facts:
accused even agreed to dispense with the direct examination of the police
 On October 22, 1996, Boco and Inocentes (Petitioners) were arrested in a officer tasked to test the substances confiscated from the accused during
buy bust operation where they were caught selling around 235 grams of the buy bust operation.
shabu to a police poseur-buyer in Mandaluyong City. The said buy bust  During the trial, the prosecution was able to properly offer as evidence the
operation came about with the tip of an anonymous informant. confiscated shabu. The separate marking of each of the 7 sachets is not a
 They were charged with a violation of Sec. 21, Article IV of the Dangerous must, and the accused also failed to deny that the marked plastic bag
Drugs Law. containing the packs of shabu were confiscated from them.
 During their arraignment, they pleaded not guilty to the charge. According
to the defense, the Petitioners were simply picking up Boco’s live-in partner On the inconsistencies of the testimonies of the police officers
when several men approached the car with their guns drawn ordering them  The Supreme Court ruled that there were no material inconsistencies in the
to alight from their car. The Petitioners were then allegedly brought to the testimonies of the 2 principal prosecution witnesses, which in this case are
Eastern Police District where they were criminally charged. the police poseur-buyer and the arresting officer who personally frisked the
body of one of the accused. Rather, they even complement each other to
 However, the trial court found the accused guilty and in ruling so, the court
give a complete picture of how the accused’s illegal sale of the regulated
gave more credit to the testimonies presented by the prosecution,
drug transpired, and how the sale led to their apprehension in flagrante
particularly that of the police poseur-buyer and one of the arresting officers.
delicto.
 Hence, the accused brought this petition before the SC. They argue that: (a)  Ultimately, their testimonies were able to establish beyond doubt that
the money used by the police to buy the shabu from the Petitioners was not illegal drugs were in the possession of both appellants, who had no
presented or identified in court; (b) the shabu itself was not properly authority to possess or sell them.
identified; and (c) there were several inconsistencies in the testimonies of  The Court also held that the testimony of the confidential informant is no
the police officers, which could have been clarified by the informant who longer necessary because by the nature of their work and for their
was not presented as a witness. protection as well, their identities cannot be revealed publicly. The
prevailing doctrine is that their testimonies are not essential for conviction,
Issue: [there were several issues but I focused on the one relating to Evidence] nor are they indispensable to a successful prosecution. With the
W/N the evidence of the prosecution was sufficient to support the conviction of testimonies of the arresting officers, they would be, after all, merely
Boco and Inocentes? YES. corroborative and cumulative.
 Lastly, the Court ruled that the trial court’s findings on the credibility of
Ruling: witnesses and their testimonies are accorded great weight and respect in
 the absence of a clear showing that some facts or circumstances of weight
or substance that could have affected the result of the case have been
overlooked, misunderstood, or misapplied.
 In this case, the testimonies were sufficient to convict Boco and Inocentes.

PETITION DENIED.