G.R. No. 258894 , January 30, 2023
GLEN ORDA Y LOYOLA, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner Glen Orda y Loyola was separately charged with violations of Sections 5 (Sale), 11 (Possession), and 12 (Possession of Paraphernalia), Article II of Republic Act No. 9165 . During trial, he expressed his intention to enter into plea bargaining pursuant to A.M. No. 18-03-16-SC (Adoption of Plea Bargaining Framework in Drug Cases). For the Section 5 and Section 11 charges, he proposed to plead guilty to two counts of violation of Section 12. For the existing Section 12 charge, he proposed to plead guilty to violation of Section 15 (Use of Dangerous Drugs). A drug dependency evaluation found him to be a drug dependent recommended for outpatient rehabilitation. The prosecution objected, citing Department of Justice (DOJ) Circular No. 27, which prescribed different allowable plea bargains, and argued that the prosecutor’s consent was required under the Rules of Criminal Procedure. The Regional Trial Court (RTC) granted petitioner’s plea bargaining proposals, ruling that A.M. No. 18-03-16-SC, issued under the Supreme Court’s rule-making power, should prevail, and that the prosecutor’s consent was sufficient. The Court of Appeals initially dismissed the People’s petition for certiorari but later granted its motion for reconsideration, annulling the RTC’s decision. It held that a valid plea to a lesser offense requires the prosecutor’s conformity and that DOJ Circular No. 27 was a valid internal guideline. Petitioner assailed this Amended Decision before the Supreme Court.

ISSUE

Whether the Regional Trial Court committed grave abuse of discretion in granting petitioner’s plea bargaining proposals over the objection of the prosecution.

RULING

The Supreme Court REVERSED the Court of Appeals’ Amended Decision. The Court held that the trial court did not commit grave abuse of discretion. It ruled that plea bargaining is a rule of procedure, and under the Constitution, the Supreme Court has the exclusive authority to promulgate rules concerning pleading, practice, and procedure in all courts. Therefore, A.M. No. 18-03-16-SC, which provides the plea bargaining framework for drug cases, prevails over the conflicting provisions of DOJ Circular No. 27. The Court further clarified that while the prosecution’s consent is generally required, the judge may overrule its objection if the plea bargaining proposal is in accordance with the Court’s framework. The case was remanded to the RTC to determine petitioner’s qualification under the Guidelines and resolve his plea bargaining proposals anew.