G.R. No. 263038 , February 17, 2025
JAN MICHAEL B. AGUILING, PETITIONER, vs. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner Jan Michael B. Aguiling was charged in three separate Informations dated October 10, 2016, for violations of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002): illegal sale of 0.0131 gram of shabu (Section 5), illegal possession of 0.0094 gram and 0.0110 gram of shabu (Section 11), and illegal possession of drug paraphernalia (Section 12). He pleaded not guilty upon arraignment, and trial ensued. During the presentation of the prosecution’s evidence, Aguiling filed a Proposal for Plea Bargaining dated May 29, 2018, citing A.M. No. 18-03-16-SC. He sought to plead guilty to the lesser offense of violation of Section 12 (possession of equipment) for the charges under Sections 5 and 11, and to Section 15 (use of dangerous drugs) for the charge under Section 12. The prosecution filed a Comment/Objection dated July 25, 2018, contending that Department of Justice (DOJ) Circular No. 027 provided that for a violation of Section 5, the accused may only plead guilty to a lesser offense under Section 11, and thus could not consent to the proposal to plead to Section 12. The Regional Trial Court (RTC) granted Aguiling’s proposal in an Order dated April 15, 2019, re-arraigned him for the downgraded offenses, and subsequently found him guilty in a Decision dated May 6, 2019, sentencing him accordingly. The People, through the Office of the Solicitor General, filed a Petition for Certiorari before the Court of Appeals (CA) assailing the RTC’s orders. The CA granted the petition in a Decision dated February 23, 2021, reversed and set aside the RTC’s orders and decision, and ordered the RTC to proceed with trial, ruling that the prosecution’s consent is required and the parties failed to reach a consensus. Aguiling’s motion for reconsideration was denied. Hence, this petition.

ISSUE

Whether the Court of Appeals erred in ruling that the Regional Trial Court acted with grave abuse of discretion in granting the petitioner’s plea bargaining proposal over the prosecution’s objection.

RULING

The Supreme Court GRANTED the petition. The Court held that the RTC did not act with grave abuse of discretion in allowing the plea bargain. The Court emphasized that a petition for certiorari under Rule 65 requires a showing of grave abuse of discretion, which is a capricious, arbitrary, or whimsical exercise of power amounting to an evasion of a positive duty or a virtual refusal to perform a legal obligation. The RTC’s decision and order permitting the plea bargain were not tainted with such abuse. The Court cited its ruling in Estipona v. Judge Lobrigo, which recognized the validity of plea bargaining in drugs cases, and the subsequent promulgation of A.M. No. 18-03-16-SC (Plea Bargaining Framework in Drugs Cases). It further noted that the Revised Amended Guidelines on Plea Bargaining for Republic Act No. 9165 , issued by the Supreme Court on May 10, 2022, and reiterated in People v. Montierro, now expressly govern plea bargaining in drugs cases and are binding on the prosecution. The Court clarified that while Section 2, Rule 116 of the Revised Rules of Criminal Procedure mentions the prosecutor’s consent, the Court’s guidelines in A.M. No. 18-03-16-SC, as amended, provide the controlling procedure. Therefore, the prosecution’s objection based solely on the non-conforming DOJ Circular could not prevail over the Court’s guidelines. The CA’s ruling was reversed, and the RTC’s orders and decision were reinstated.