Title
Biron vs. People
Case
G.R. No. 258126
Decision Date
Apr 19, 2023
Petitioners charged under RA 9165 sought plea bargains; RTC allowed, CA reversed. SC ruled trial courts may override prosecution's unsubstantiated objections, remanding for evidence-based review.
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Case Digest (G.R. No. 258126)

Facts:

Charges Against the Petitioners

The petitioners, Jonathan Gabriel Biron, Arjay Mendez, and Eric Ebuenga Palomer, were charged with violations of Sections 5 and 11, Article II of Republic Act No. (RA) 9165 (Comprehensive Dangerous Drugs Act of 2002) in three separate Informations dated November 11, 2018. The charges stemmed from incidents on November 10, 2018, in Tabaco City, Albay.

  • Criminal Case No. T-7306 (Biron): Biron was charged with selling and delivering 0.1015 grams of methamphetamine hydrochloride ("shabu") to a poseur-buyer.
  • Criminal Case No. T-7307 (Biron): Biron was charged with possessing 0.0738 grams of shabu.
  • Criminal Case No. T-7308 (All Petitioners): All three petitioners were charged with selling and delivering 0.0913 grams and 0.0855 grams of shabu, respectively, in a conspiracy.

Plea Bargaining Attempt

The petitioners initially pleaded not guilty but later filed motions to enter into a plea bargain and plead guilty to a lesser offense under Section 12, Article II of RA 9165 (Possession of Equipment, Apparatus, and Other Paraphernalia for Dangerous Drugs). They cited Supreme Court Administrative Matter (A.M.) No. 18-03-16-SC, which allows plea bargaining in drug cases.

The Deputy City Prosecutor opposed the motions, arguing that plea bargaining requires the concurrence of the public prosecutor and arresting officers.

RTC Decision

The Regional Trial Court (RTC) granted the motions and allowed the petitioners to plead guilty to the lesser offense. The RTC found the petitioners guilty of violating Section 12 of RA 9165 and imposed penalties, including fines and rehabilitation programs.

The prosecution moved for reconsideration, but the RTC denied the motion, citing the Supreme Court's authority over plea bargaining frameworks.

CA Decision

The Court of Appeals (CA) reversed the RTC's decision, ruling that plea bargaining requires mutual agreement between the prosecution and the accused. The CA held that the RTC committed grave abuse of discretion by allowing the plea bargain despite the prosecution's objection.

Issue:

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Ruling:

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Ratio:

  1. Plea Bargaining Framework: The Supreme Court's plea bargaining framework in drug cases (A.M. No. 18-03-16-SC) allows accused individuals to plead guilty to lesser offenses under Section 12 of RA 9165, provided the quantity of drugs involved is within specified limits.
  2. Prosecution's Objection: The prosecution's objection to plea bargaining must be supported by evidence, such as the accused being a recidivist, habitual offender, or having strong evidence of guilt. If the objection is based solely on internal DOJ guidelines, the court may overrule it.
  3. Discretion of the Court: Plea bargaining is subject to the court's discretion, and the prosecution's consent is not always required if the objection lacks merit.
  4. Remand for Further Proceedings: The case was remanded to the RTC to determine if the prosecution's objection is supported by evidence, such as the petitioners' criminal history or the strength of the evidence against them.

Conclusion:

The Supreme Court emphasized that plea bargaining in drug cases must align with the Court's framework, and trial courts have the discretion to approve plea bargains even over the prosecution's objection if the objection is not substantiated. The case was remanded to the RTC for further evaluation of the prosecution's objections.


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