G.R. No. 243190 . August 28, 2019.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. DENNIS SARABIA Y REYES, ACCUSED-APPELLANT.

FACTS

Accused-appellant Dennis Sarabia y Reyes was charged with violations of Sections 5 (Sale) and 11 (Possession) of Republic Act No. 9165 (The Comprehensive Dangerous Drugs Act of 2002). The charges stemmed from a buy-bust operation on June 30, 2013, in Laoag City. A confidential informant arranged a deal where a poseur-buyer would purchase PHP 1,000.00 worth of shabu. During the transaction, Sarabia allegedly sold one plastic sachet containing 0.0392 gram of methamphetamine hydrochloride to the poseur-buyer. Upon his arrest, six additional plastic sachets containing 3.219 grams of shabu were recovered from his person. The Regional Trial Court convicted Sarabia, a ruling affirmed by the Court of Appeals.

ISSUE

Whether the prosecution successfully proved the guilt of the accused-appellant beyond reasonable doubt, particularly in establishing the integrity and evidentiary value of the seized dangerous drugs through strict compliance with the chain of custody rule under Section 21 of RA 9165.

RULING

The Supreme Court REVERSED the convictions and ACQUITTED accused-appellant Dennis Sarabia y Reyes. The Court found a broken chain of custody, which compromised the integrity of the evidence. The buy-bust team failed to strictly comply with the witness requirement during the physical inventory and photographing of the seized items as mandated by law. The prosecution admitted that no representatives from the Department of Justice (DOJ) or any elected public official were present during the inventory. Only a barangay chairman and media representatives signed the certificate. The law requires the presence of insulating witnesses—specifically, an elected public official, a representative from the DOJ, and a representative from the media—to deter planting or tampering of evidence. The prosecution’s mere invocation of “justifiable grounds” for non-compliance was insufficient, as it failed to provide a credible explanation for the absence of the required witnesses and to show earnest efforts to secure their presence. Consequently, the identity and integrity of the corpus delicti were not preserved with moral certainty, creating reasonable doubt. The Court emphasized that in drugs cases, the State carries the heavy burden of proving an unbroken chain of custody; any substantial gap leads to acquittal.