Facts:

• Gabriel Campugan Cabriole and co-accused Daniel Gumanit Abad were charged under Sections 5 and 11 of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
• The incident took place on October 16, 2016, at around 1:57 PM in Purok 4, Barangay 18-A, Gingoog City, Philippines.
• Cabriole allegedly sold a sachet of shabu (0.0686 grams) to police poseur-buyer PO1 Armand Lenard Do for 500 pesos.
• Upon his arrest, Cabriole was found in possession of three additional sachets of shabu, totaling 0.1523 grams.
• The Regional Trial Court (RTC) convicted Cabriole, and the Court of Appeals upheld this decision.
• The prosecution's case relied on testimonies from police officers and witnesses, while the defense argued that the evidence was fabricated.

Issue:

• (Unlock)

Ruling:

• The Supreme Court found the appeal partly meritorious.
• It upheld the warrantless arrest and the search and seizure of evidence.
• Cabriole was acquitted of the illegal sale of dangerous drugs under Section 5 due to the prosecution's failure to prove an unbroken chain of custody.
• Cabriole was convicted of illegal possess...(Unlock)

Ratio:

• The removal of the poseur-buyer's sunglasses was considered a valid signal indicating the completion of the drug sale, justifying the warrantless arrest.
• The presence of the poseur-buyer and the confidential informant was sufficient to establish the elements of the crime, even without direct observation by other officers.
• Warrantless arrests are permissible when an offense occurs in ...continue reading