G.R. No. 247575 , November 16, 2020
PEOPLE OF THE PHILIPPINES, PETITIONER, VS. EDWIN REAFOR Y COMPRADO, RESPONDENT.

FACTS

Respondent Edwin Reafor was charged with Illegal Sale of Dangerous Drugs under Section 5 of RA 9165. During trial, he filed a Motion to Plea Bargain, seeking to plead guilty to the lesser offense of violation of Section 12 (Possession of Equipment, Instrument, etc.) as per Supreme Court Administrative Matter (A.M.) No. 18-03-16-SC. The prosecution opposed, citing Department of Justice (DOJ) Circular No. 27, which mandated that the acceptable plea for the charged crime was under Section 11 (Possession of Dangerous Drugs). The Regional Trial Court (RTC) granted respondent’s motion, prioritizing the Supreme Court’s procedural rule over the DOJ circular. Respondent was re-arraigned, pleaded guilty to Section 12, and was convicted.
The People, through the Office of the Solicitor General (OSG), filed a petition for certiorari under Rule 65 before the Court of Appeals (CA) assailing the RTC’s orders and judgment. The CA dismissed the petition on procedural grounds, finding it was filed out of time and that no prior motion for reconsideration was filed with the RTC, a condition precedent for a Rule 65 petition. The OSG’s motion for reconsideration was denied.

ISSUE

Whether the CA erred in dismissing the petition for certiorari on procedural grounds.

RULING

The Supreme Court granted the petition, reversing the CA. While the CA correctly identified procedural lapses, the Court exercised its equity jurisdiction to disregard them, as rigid application of procedural rules would override substantial justice given the void judgment rendered by the RTC. The core legal issue was the validity of the plea bargain.
The RTC committed grave abuse of discretion. Plea bargaining requires the mutual consent of both the prosecution and the accused under Section 2, Rule 116 of the Revised Rules of Criminal Procedure. The prosecution’s express opposition rendered the plea bargain invalid. The Court clarified that A.M. No. 18-03-16-SC provides a framework for plea bargaining but does not remove the requirement of prosecutorial consent. The RTC’s grant of the motion over the prosecution’s objection was a violation of this fundamental rule.
Consequently, the RTC’s orders and judgment, being products of an invalid plea bargain, are void ab initio. A void judgment never attains finality and can be assailed at any time. The case was remanded to the RTC for the continuation of the trial on the original charge of Illegal Sale. This resumption does not violate double jeopardy, as the respondent’s conviction under a void proceeding is deemed a nullity.