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People of The Philippines Vs de Guzman - Case Digest

The trial involved a drug peddling case where the accused was arrested in a buy-bust operation. The accused claimed alibi as a defense. The trial court found the prosecution witnesses, two police officers, credible and convicted the accused. The Supreme Court affirmed, stating there is a presumption of regularity of official acts that was not rebutted by clear evidence. Minor irregularities in paperwork after the arrest did not outweigh the presumption.

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Niño Raymond Mendoza
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87 views1 page

People of The Philippines Vs de Guzman - Case Digest

The trial involved a drug peddling case where the accused was arrested in a buy-bust operation. The accused claimed alibi as a defense. The trial court found the prosecution witnesses, two police officers, credible and convicted the accused. The Supreme Court affirmed, stating there is a presumption of regularity of official acts that was not rebutted by clear evidence. Minor irregularities in paperwork after the arrest did not outweigh the presumption.

Uploaded by

Niño Raymond Mendoza
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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People of the Philippines vs De Guzman (229 SCRA 795)

Facts:
Accused-appellant has been in the watch list of the police as a prohibited drug peddler. On two
occasions, they tried to entrap him without any success. The third time, however, his luck ran
out. The third entrapment operation against the accused was led by PO3 Arnaldo Manzon and
Patrolman Eduardo Chiapoco of the Western Police District (WPD). The buy-bust operation led
to the accused’s arrest and was subsequently charged with the information for the violation of
Section 15, Article III of Republic Act 6425. During the trial, the prosecution was able to estab-
lish the necessary quantum of evidence required by law to prove the elements of the crime
while the accused-appellant relied on alibi as his main defense against the allegations of the
prosecution hence the RTC ruled in favor of the prosecution effectively convicting the accused.

Issue:
WHETHER OR NOT THE TRIAL COURT ERRED IN UPHOLDING THE CREDIBILITY OF THE
POLICEMEN WITNESSES FOR THE PROSECUTION AND IN CONVICTING THE ACCUSED
ON THE BASIS THEREOF.

Ruling:
No, RTC ruled correctly.

SC in resolving the case defined the disputable presumption of regularity wherein it states that
the presumption of regularity of official acts may be rebutted by affirmative evidence of irregular-
ity or failure to perform a duty. The presumption, however, prevails until it is overcome by no
less than clear and convincing evidence to the contrary. Thus, unless the presumption is rebut-
ted, it becomes conclusive. Every reasonable intention will be made in support of the presump-
tion and in case of doubt as to an officer's act being lawful or unlawful, construction should be in
favor of its lawfulness.

The RTC ruled correctly with regards to the police officers presumably acting in regularity. The
failure of Pat. Chiapoco to read the joint Affidavit of Apprehension before signing it is of de min-
imis importance. This irregularity happened after the buy-bust operation had already been con-
cluded and where the accused-appellant was caught in flagrante delicto. The accused-appellant
failing to provide strong and convincing evidence to rebut the disputable presumption of regular-
ity cannot therefore claim irregularity in government duty.

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