Case Digest (G.R. No. 221457)
Facts:
People of the Philippines v. Gilbert Sebilleno y Casabar, G.R. No. 221457, January 13, 2020, Supreme Court Third Division, Leonen, J., writing for the Court.The case arose from two Informations filed after a June 4, 2008 buy‑bust operation in Barangay Alabang, Muntinlupa City. The prosecution charged Gilbert Sebilleno y Casabar with illegal sale of methamphetamine hydrochloride (shabu), and charged Kyle Enrique y Damba with illegal possession; both accused pleaded not guilty at arraignment. During pre‑trial the prosecution admitted the identity of Sebilleno, the jurisdiction of the court, the involvement of P/Chief Insp. Maridel Cuadra Rodis as a PNP forensic chemist, and the existence of the Request for Laboratory Examination and Physical Science Report No. D‑228‑08.
The prosecution’s evidence described a surveillance and a poseur‑buyer operation in which PO1 Julaton bought a marked P500 bill from Sebilleno and received a sachet later marked “GSC,” while PO1 Ocampo arrested Enrique and retained a sachet marked “KE.” The officers conducted an inventory and took photographs at the police station witnessed by Raquel L. Dilao, a local government employee; the seized items were submitted to the PNP Crime Laboratory the same evening and tested positive for shabu. Sebilleno testified in his defense that he was awakened at home, coerced at gunpoint, taken to the police station, and forced to admit being “Boy Trolly”; he denied selling the drugs.
The Regional Trial Court (Muntinlupa, Branch 204) in a September 30, 2013 Decision convicted Sebilleno beyond reasonable doubt for violation of Section 5, Article II of Republic Act No. 9165 and sentenced him to life imprisonment and a fine of P500,000; Enrique was acquitted for insufficiency of evidence. The Court of Appeals, in a January 26, 2015 Decision, affirmed the RTC in toto, crediting the police officers’ testimony and excusing deviations from Section 21 of RA 9165 on the ground that tanods refused to witness inventories because the area was allegedly a “notorious Muslim community.” Sebilleno filed a Notice of Appeal; the Court of Appeals gave due course and elevated the records to the Supreme Court, which noted the case and permitted supplemental briefs (both parties ultimately manifested they would not file supplemental briefs).
At issue before the Supreme Court was whether the prosecution proved Sebilleno’s guilt beyond reasonable doubt pa...(Pro-only)
Issues:
- Did the prosecution prove beyond reasonable doubt the identity and integrity of the seized drug — i.e., show an unbroken chain of custody under Section 21 of RA 9165 — to sustain Sebilleno’s conviction for illegal sale of da...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)