GR 266439; (August, 2023) (Digest)
G.R. No. 266439, August 30, 2023
Teresito Radonis Quiqui, Petitioner, vs. People of the Philippines, Respondent.
FACTS
Petitioner Teresito Radonis Quiqui was charged with Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. 9165 for selling 0.10 gram of shabu. Upon arraignment, he pleaded not guilty. During trial, he filed a motion to enter into a plea bargain, praying to plead guilty to the lesser offense of Illegal Possession of Drug Paraphernalia under Section 12 of the same law, pursuant to A.M. No. 18-03-16-SC. The prosecution opposed, citing Department of Justice (DOJ) Circular No. 027, which stated that the acceptable plea bargain for Section 5 violations involving less than five grams of shabu was to Section 11 (Illegal Possession). The Regional Trial Court (RTC) approved the plea bargain, considering the small quantity (0.10 gram) and the rationale of A.M. No. 18-03-16-SC. Upon re-arraignment, petitioner pleaded guilty to Section 12, and the RTC rendered a judgment convicting him thereof. The prosecution, through the Office of the Solicitor General, filed a petition for certiorari before the Court of Appeals (CA). The CA reversed the RTC, declaring its orders and judgment void, and ordered the continuation of the trial for the original charge. Petitioner’s motion for reconsideration was denied.
ISSUE
Whether the Court of Appeals seriously erred in declaring the petitioner’s plea-bargaining proposal void.
RULING
The Supreme Court granted the petition. It held that the plea-bargaining proposal was valid. The Court took judicial notice of DOJ Circular No. 018 (dated May 10, 2022), which revoked DOJ Circular No. 027 and aligned with the plea-bargaining framework in A.M. No. 18-03-16-SC. Under this new circular and the Court’s framework, an accused charged with illegal sale of 0.01 to 0.99 gram of shabu may plea bargain to Illegal Possession of Drug Paraphernalia under Section 12. The Court emphasized that plea bargaining is a rule of procedure falling under its exclusive rule-making power under the Constitution. While the prosecution’s consent is required, its opposition is treated as a continuing objection to be resolved by the trial court, which retains the sound discretion to approve or deny a plea bargain. The RTC properly exercised this discretion by considering the parties’ submissions and the guidelines in A.M. No. 18-03-16-SC. Therefore, the CA erred in declaring the RTC’s approval of the plea bargain and the consequent judgment void.