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People vs. Saragena

PEOPLE OF THE PHILIPPINES PLAINTIFF-APPELLEE. VS. ABUNDIO M. SARAGENA, ACCUSED-APPELLANT.

G.R. No. 210677 | 2017-08-23

DECISION
 
LEONEN, J.:
 
When the quantity of the confiscated substance is miniscule, the requirements of Section 21 of Republic Act No. 9165, otherwise known as the Comprehensive Dangerous Drugs Act of 2002, must be strictly complied with.[1]

The prosecution's failure to present the police officer who acted as the poseur-buyer in the buy-bust operation, which allegedly involved 0.03 grams of shabu, coupled with the improbability that the two (2) apprehending police officers witnessed the transaction at night time, engenders reasonable doubt on the guilt of the accused. The prosecution's failure to sufficiently establish the...