GR L 22797; (September, 1966) (Digest)
March 12, 2026GR L 24873; (September, 1966) (Digest)
March 12, 2026G.R. No. 182296 April 7, 2009
Susan Sales y Jimena, Petitioner, vs. People of the Philippines, Respondent.
FACTS
Petitioner Susan Sales y Jimena was charged with violating Section 5, Article II of R.A. No. 9165 (The Comprehensive Dangerous Drugs Act of 2002) for allegedly selling 0.14 gram of shabu during a buy-bust operation on November 5, 2002, in Quezon City. The prosecution’s version, primarily from PO1 Teresita B. Reyes, stated that an informant reported petitioner was peddling drugs on Scout Tobias Street. A team was formed with PO1 Reyes as the poseur-buyer using a marked ₱500 bill. The informant introduced PO1 Reyes to petitioner, who asked how much she would buy. Upon receiving the money, petitioner handed over a plastic sachet. Petitioner was then arrested, and the marked money was recovered. The sachet was later marked and found positive for shabu. The defense presented a different account, claiming petitioner was illegally arrested on November 4, 2002, at a friend’s house in Kamias, Quezon City, where armed men (policemen) barged in without a warrant, searched the house, took her belongings, and detained her. The Regional Trial Court convicted petitioner, sentencing her to life imprisonment and a ₱500,000 fine. The Court of Appeals affirmed the conviction.
ISSUE
Whether the prosecution proved petitioner’s guilt for illegal sale of dangerous drugs beyond reasonable doubt.
RULING
The Supreme Court REVERSED the Court of Appeals decision and ACQUITTED petitioner. The Court found the testimony of PO1 Reyes improbable and incredible. It was contrary to common experience for a drug peddler to sell openly on a busy street in broad daylight and to readily transact with a complete stranger without hesitation. Furthermore, the police failed to comply with the chain of custody requirement under R.A. No. 9165, which is essential to establish the identity and integrity of the seized drug as the corpus delicti. The omission was fatal to the prosecution’s case. Petitioner was ordered immediately released unless lawfully held for another cause.