Case Digest (G.R. No. 262664)
Facts:
Manuel Lopez Bason v. People of the Philippines, G.R. No. 262664, October 03, 2023, Supreme Court En Banc, Inting, J., writing for the Court. Petitioner Manuel Lopez Bason was charged by Informations with violations of Sections 5 and 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) in two cases (Criminal Case Nos. C-288-16 and C-289-16). He pleaded not guilty at arraignment, and trial commenced. On June 5, 2018, after the prosecution had rested, Bason filed a plea-bargaining proposal offering to plead guilty instead to two counts of violation of Section 12, Article II of RA 9165.The Office of the City Prosecutor of Roxas City (OCP‑Roxas City) opposed the plea bargaining proposal on several grounds, including that (a) it had rested and had strong evidence of guilt, and (b) DOJ Department Circular No. 27 (2018) disallowed plea bargaining for Section 5 offenses, so the proposed plea exceeded DOJ guidelines. Despite the prosecution’s objection, Branch 18, Regional Trial Court (RTC), Roxas City, issued Orders dated November 29, 2018 (granting the plea bargaining proposal), December 3, 2018 (finding Bason guilty of two counts of Section 12 and imposing penalties), and January 23, 2019 (denying the prosecution’s motion for reconsideration). In its November 29, 2018 Order the RTC evaluated the prosecution’s evidence and found procedural lapses in the chain of custody that cast doubt on the evidence’s integrity.
Acting for the State, the Office of the Solicitor General (OSG) filed a petition for certiorari under Rule 65 before the Court of Appeals (CA) alleging grave abuse of discretion by the RTC in approving the plea bargain over the prosecution’s objection. On April 13, 2021, the CA granted the Rule 65 petition, reversed and set aside the RTC Orders, and ordered the RTC to proceed with trial. Bason filed a Petition for Review on Certiorari under Rule 45 to...(Pro-only)
Issues:
- Did the Court of Appeals err in ruling that the Regional Trial Court committed grave abuse of discretion in approving Bason’s plea‑bargaining proposal over the prosecution’s objection?
- Does DOJ Department Circular No. 018 (2022) cure the issue of lack of prosecution consent in plea bargaining cases previously premised on DOJ...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)