Criminal Law

People of the Philippines vs Ryan Blanco

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G.R. No. 193661 – 716 Phil. 408 – 703 SCRA 597 – Criminal Law – Special Penal Laws – Anti-Dangerous Drugs Act – Confidential Informant

Remedial Law – Evidence – Testimonial Evidence – Presentation of Confidential Informant

Ryan Blanco was convicted for violations of the Dangerous Drugs Act (R.A. 9165). He was found guilty for the illegal sale and possession of dangerous drugs (shabu). He appealed his conviction on the ground that the prosecution did not establish his guilt as there were inconsistencies in the testimonies of the prosecution witnesses as compared with their affidavits.

There was also a question as to the non-presentation of the confidential informant who was the alleged contact of Blanco prior to the sale.

ISSUE: Whether or not Blanco’s conviction should be reversed.

HELD: No. The Supreme Court ruled: Inconsistencies in the testimonies of prosecution witnesses with respect to minor details and collateral matters do not affect the substance of their declaration, its veracity or the weight of their testimonies.

Anent the issue of the non-presentation of the confidential informant: The non- presentation of the confidential informant is not fatal to the prosecution. Informants are usually not presented in court because of the need to hide their identity and maintain their valuable service to the police.

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