Pueblo v. Acevedo Estrada
150 P.R. Dec. 84 (2000)
Rule of Law:
When the prosecution's case relies almost exclusively on the uncorroborated testimony of an undercover agent, and the defense presents substantial evidence challenging that agent's credibility and motives, the trial court must give a special instruction for the jury to examine that testimony with particular caution. Failure to do so constitutes reversible error.
Facts:
- Fernando L. Collazo, a bailiff, began acting as an undercover agent in an investigation into alleged corruption within the Puerto Rico judiciary.
- After his cover was suspected at the San Juan Judicial Center, Collazo was transferred to the Bayamón Judicial Center on November 3, 1993.
- On November 17, 1993, Collazo approached fellow bailiff Pedro Acevedo Estrada, stating he was depressed and 'would take anything'. Acevedo Estrada allegedly replied that he had found some marijuana.
- The following day, Collazo alleged that Acevedo Estrada passed him a small bag of marijuana in a busy courthouse hallway by touching his genitals and placing the bag in his shirt pocket.
- Later that afternoon, Collazo claimed he paid Acevedo Estrada $15 for the marijuana in the courthouse's holding cell area, despite no price having been previously discussed.
- Evidence was presented showing that Collazo and Acevedo Estrada had a prior negative personal relationship stemming from a work-related incident, to the point that they did not speak to each other.
- Collazo had previously been fired from his job as a corrections officer for criminal conduct and had deliberately omitted this fact on his application to become a bailiff.
Procedural Posture:
- Pedro Acevedo Estrada was charged in the Superior Court of Puerto Rico, a trial court, with possession of a controlled substance with intent to distribute.
- During the trial, the defense requested a special jury instruction on how to evaluate the testimony of the prosecution's main witness, an undercover agent.
- The trial court judge denied the defense's request for the special instruction.
- A jury found Acevedo Estrada guilty by a vote of 9 to 2, with one member abstaining.
- The trial court sentenced Acevedo Estrada to five years in prison but granted him bail pending appeal, stating the appeal had a high probability of success.
- Acevedo Estrada, as appellant, appealed his conviction to the Supreme Court of Puerto Rico, the highest appellate court.
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Issue:
Does a trial court commit reversible error by refusing to give a special jury instruction on how to evaluate an undercover agent's testimony with caution, when the prosecution's entire case rests on that agent's uncorroborated account and the defense has presented significant evidence of the agent's mendacity and improper motives?
Opinions:
Majority - Associate Justice Rebollo López
Yes. A trial court commits reversible error by refusing to give a special jury instruction to evaluate an undercover agent's testimony with caution when the state's case rests almost entirely on that testimony and the defense introduces significant evidence of the agent's mendacity and personal bias. The court reasoned that the testimony of undercover agents must be scrutinized with special rigor. When the central theory of the defense is to attack the credibility of the sole incriminating witness, the defendant is entitled to an instruction that guides the jury in this specific evaluation. The failure to provide the requested instruction was prejudicial, not harmless error, especially given the close 9-2 jury vote for conviction. The court further bolstered its conclusion by highlighting the extreme fragility of the prosecution's case, which consisted of the uncorroborated and 'inherently improbable' testimony of a witness with a documented history of dishonesty and a demonstrated personal animosity toward the defendant.
Analysis:
This decision reinforces the principle that a defendant's right to a fair trial includes the right to have the jury properly instructed on how to weigh uniquely problematic evidence. It establishes a strong precedent in Puerto Rican law that when a case hinges on the word of a single undercover agent whose credibility is substantially impeached, a general instruction on witness credibility is insufficient. The ruling serves as a crucial judicial safeguard against wrongful convictions based on potentially fabricated or 'stereotyped' testimony from agents who may have personal motives or are otherwise unreliable, ensuring that appellate courts can and will intervene when the evidence presented leaves 'serious, reasonable, and well-founded doubts' about a defendant's guilt.
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