Case Digest (G.R. No. 226679) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Salvador Estipona, Jr. y Asuela v. Hon. Frank E. Lobrigo (G.R. No. 226679, August 15, 2017), petitioner Salvador A. Estipona, Jr. was charged before the Regional Trial Court (RTC), Branch 3, Legazpi City, Albay, with violation of Section 11, Article II of Republic Act No. 9165 (Possession of Dangerous Drugs). On March 21, 2016, he allegedly had in his control a sachet containing 0.084 gram of methamphetamine hydrochloride (shabu). On June 15, 2016, Estipona moved to withdraw his not guilty plea and enter into a plea bargaining agreement for a lesser offense—possession of drug paraphernalia under Section 12, Article II of RA 9165—citing his first-time offender status and the minimal drug quantity. The prosecution opposed, invoking Section 23 of RA 9165, which prohibits plea bargaining in all drug cases. On July 12, 2016, RTC Judge Lobrigo denied the motion, deeming it a constitutional question beyond the lower court’s authority. A motion for reconsideration was likewise denied Case Digest (G.R. No. 226679) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Charge
- Petitioner Salvador A. Estipona, Jr. was charged in RTC Branch 3, Legazpi City with unlawful possession of 0.084 g of methamphetamine hydrochloride (shabu) under Section 11, Article II of R.A. No. 9165.
- He pleaded not guilty and was arraigned on the Information dated March 21, 2016.
- Motion for Plea Bargaining and RTC Ruling
- On June 15, 2016, Estipona moved to withdraw his not guilty plea and enter a plea of guilty to the lesser offense of possession of paraphernalia under Section 12, Article II of R.A. No. 9165, invoking rehabilitation as a first-time offender and minimal quantity seized.
- The prosecution opposed, citing Section 23 of R.A. No. 9165, which prohibits plea bargaining for all drug offenses.
- On July 12, 2016, RTC Judge Lobrigo denied the motion, holding that Section 23’s plea-bargaining ban encroaches on the Supreme Court’s exclusive rule-making power over procedure. A motion for reconsideration was likewise denied on July 26, 2016.
- Petition to the Supreme Court
- Estipona filed a petition for certiorari and prohibition with urgent prayer for injunctive relief, raising constitutional challenges to Section 23 of R.A. No. 9165.
- The Office of the Solicitor General argued procedural defects (non-impleading of Congress, collateral attack, lack of standing) and urged dismissal.
- The Supreme Court en banc set aside technical objections, exercised its power to suspend rules, and proceeded to resolve the substantive issues.
Issues:
- Whether Section 23 of R.A. No. 9165, prohibiting plea bargaining in all drug-related offenses, violates the constitutional right to equal protection.
- Whether Section 23 infringes upon the Supreme Court’s exclusive power to promulgate rules of procedure under Article VIII, Section 5(5) of the 1987 Constitution.
- Whether the RTC committed grave abuse of discretion amounting to lack or excess of jurisdiction by refusing to declare Section 23 unconstitutional.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)