G.R. No. 257733 , January 11, 2023
James Billoso y Obligar, Petitioner, vs. People of the Philippines, Respondent.

FACTS

James Billoso y Obligar (Billoso) and Dave Billoso y Capapas were charged with violation of Section 5 (Sale of Dangerous Drugs) in relation to Section 26 (Conspiracy) of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for selling one sachet of shabu weighing 0.0200 gram. Billoso was separately charged with violation of Section 11 (Possession of Dangerous Drugs) of the same law for possessing four sachets of shabu with a total weight of 0.3934 grams. Upon arraignment, they pleaded not guilty but subsequently submitted a Proposal for Plea Bargaining, expressing willingness to plead guilty to the lesser offense of violation of Section 12 (Possession of Equipment, Instrument, Apparatus and Other Paraphernalia for Dangerous Drugs) for all charges. The prosecution objected, citing Department of Justice (DOJ) Circular No. 027-18 which directed non-acceptance of such plea bargains for Section 5 violations and asserting that the evidence was sufficient for conviction on the original charges. The Regional Trial Court (RTC) granted the plea bargaining proposal, overruling the prosecution’s objection, and convicted Billoso of two counts of violation of Section 12. The RTC reasoned that the Supreme Court’s Plea Bargaining Framework in Drugs Cases (A.M. No. 18-03-16-SC) prevailed over the DOJ Circular. The Office of the Solicitor General filed a Petition for Certiorari with the Court of Appeals (CA). The CA granted the petition, reversed the RTC Decision and Order, and directed the RTC to proceed with the original charges. Billoso’s motion for reconsideration was denied.

ISSUE

Whether the Court of Appeals erred in annulling the Decision and Order of the Regional Trial Court that approved Billoso’s plea bargaining proposal and ordered the reinstatement and continuation of the criminal cases on the original charges.

RULING

The Supreme Court DENIED the Petition, affirming the Court of Appeals. The Petition was without merit. The Supreme Court held that while the prosecution’s objection based solely on the inconsistency with DOJ Circular No. 027-18 was rendered moot by the subsequent DOJ Circular No. 18 (2022) which amended the guidelines to conform with the Supreme Court’s Plea Bargaining Framework, the RTC committed grave abuse of discretion in granting the plea bargain. The RTC failed to consider and resolve the prosecution’s second ground for objection: that there was sufficient evidence to convict Billoso of the offenses originally charged. A plea bargain requires mutual agreement between the prosecution and the accused. The prosecution’s valid objection, based on its assessment of the evidence’s strength, precluded the court from imposing a plea bargain over the State’s objection. The RTC’s grant of the plea bargain absent such mutual agreement and without ruling on the sufficiency of evidence constituted grave abuse of discretion. Therefore, the CA correctly annulled the RTC’s orders and reinstated the original charges for trial.