Title
Estipona, Jr. y Asuela vs. Lobrigo
Case
G.R. No. 226679
Decision Date
Aug 15, 2017
Petitioner challenged Sec. 23 of R.A. 9165, prohibiting plea bargaining in drug cases, as unconstitutional. SC ruled it encroached on judicial rule-making power, invalidating the provision.

Case Digest (G.R. No. 226679)
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)

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