G.R. No. 262664 , October 3, 2023
Manuel Lopez Bason, Petitioner, vs. People of the Philippines, represented by the Office of the Solicitor General, Respondent.

FACTS

Manuel Lopez Bason was charged with Violation of Section 5 (Sale) and Section 11 (Possession) of Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) in two separate Informations. After pleading not guilty and during trial, Bason proposed to plead guilty to two counts of Violation of Section 12 (Possession of Equipment, Instrument, Apparatus and Other Paraphernalia for Dangerous Drugs) of the same law. The Office of the City Prosecutor of Roxas City opposed the plea bargaining proposal, arguing, among others, that under Department of Justice (DOJ) Department Circular No. 027, an accused can only be allowed to plead guilty from Section 5 to Section 11, and that the prosecution’s consent was mandatory. The Regional Trial Court (RTC) granted Bason’s plea bargaining proposal over the prosecution’s objection, allowed him to withdraw his not guilty plea, and found him guilty of two counts of Violation of Section 12. The RTC, in its Order, detailed procedural lapses in the chain of custody committed by the police officers which cast doubt on the integrity of the evidence. The prosecution’s motion for reconsideration was denied. The Office of the Solicitor General (OSG) filed a petition for certiorari before the Court of Appeals (CA), which granted the petition, reversed the RTC Orders, and ordered the trial to proceed. Bason’s motion for reconsideration was denied.

ISSUE

1. Whether the CA erred in ruling that the RTC committed grave abuse of discretion in approving Bason’s plea bargaining proposal over the objection of the prosecution.
2. Whether DOJ Department Circular No. 018 cured the issue on the lack of consent in plea bargaining cases.

RULING

The Supreme Court granted the petition, reversing the CA Decision and Resolution.
1. The Court’s Plea Bargaining Framework in Drugs Cases (A.M. No. 18-03-16-SC) takes precedence over any DOJ Department Circular or similar issuance. The Court recognized that DOJ Department Circular No. 018 reconciled inconsistencies with the Court’s framework, and under both, the acceptable plea for a violation of Section 5 is Section 12. Therefore, the prosecution’s objection based on non-conformity with DOJ guidelines was rendered moot.
2. While plea bargaining generally requires the mutual agreement of the parties, its approval is ultimately subject to the sound discretion of the court. The trial court may overrule a prosecution objection based solely on non-conformity with internal DOJ guidelines if the proposal conforms to the Court’s framework and the evidence and circumstances of the case. However, the court must hear and rule on the merits of a valid objection supported by evidence, such as the accused being a recidivist or the evidence of guilt being strong.
3. The trial court must evaluate the accused’s character and the weight of the prosecution’s evidence before approving a plea bargain. The presence of conditions like the accused being a recidivist or the evidence of guilt being strong disqualifies the accused. In this case, the RTC properly evaluated the evidence and found procedural lapses in the chain of custody that weakened the prosecution’s case. The RTC’s discretion to approve the plea bargain, after finding the evidence did not establish guilt beyond reasonable doubt for the original charges, was not gravely abused.
The Supreme Court held that the RTC did not commit grave abuse of discretion in granting the plea bargaining proposal.