Title
Manuel Lopez Bason vs. People, represented by the Office of the Solicitor General
Case
G.R. No. 262664
Decision Date
Oct 3, 2023
Manuel Lopez Bason charged under RA 9165 for drug offenses proposed plea bargaining, opposed by prosecution. RTC approved, CA reversed, SC upheld RTC, citing procedural lapses and primacy of court's plea bargaining framework.

Case Digest (G.R. No. 262664)
Expanded Legal Reasoning Model

Facts:

  • Parties and Case Origin
    • Manuel Lopez Bason (petitioner) was charged with violations of Sections 5 and 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002).
    • The case arose from accusations that on July 22, 2016, in Roxas City, Bason sold and possessed methamphetamine hydrochloride (shabu).
    • Two separate Criminal Cases were filed: C-288-16 (sale of shabu to a poseur buyer) and C-289-16 (possession of shabu and drug paraphernalia).
  • Proceedings at the Trial Court (RTC)
    • Upon arraignment, Bason pleaded "Not Guilty" to the charges.
    • On June 5, 2018, Bason submitted a plea bargaining proposal to plead guilty to two counts of violation of Section 12, Article II of RA 9165 (possession of drug paraphernalia), a lesser offense.
    • The Office of the City Prosecutor of Roxas City (OCP) opposed the plea bargain on grounds including:
      • The prosecution had already rested with strong evidence.
      • DOJ Department Circular No. 027 limits acceptable plea bargaining pleas between Sections 5 and 11 only.
      • The plea bargain would undermine the case’s thorough resolution.
      • There was probable cause for multiple charges under RA 9165.
    • Despite the opposition, on November 29, 2018, the RTC granted Bason’s plea bargaining proposal over prosecution’s objection, allowing withdrawal of the "not guilty" plea and acceptance of guilty plea to lesser offenses.
    • On December 3, 2018, RTC rendered judgment imposing imprisonment of 2 years 4 months to 4 years and a fine of ₱10,000 for each count.
    • Prosecution moved for reconsideration, arguing for the mandatory consent of the prosecution for plea bargains, but the RTC denied the motion on January 23, 2019.
  • Court of Appeals Proceedings
    • The Office of the Solicitor General (OSG), representing the State, filed a petition for certiorari before the Court of Appeals (CA) alleging grave abuse of discretion by the RTC in approving the plea bargain without prosecution’s consent.
    • On April 13, 2021, CA granted the petition, reversed the RTC orders, and ordered the trial to proceed with reasonable dispatch.
    • CA denied Bason’s motion for reconsideration on May 26, 2022.
  • Petition to the Supreme Court
    • Bason filed a Petition for Review on Certiorari under Rule 45, disputing:
      • The CA’s ruling that RTC committed grave abuse by granting plea bargain over prosecution’s objection.
      • The CA’s interpretation that lack of prosecution’s consent renders plea bargains void under A.M. No. 18-03-16-SC (Plea Bargaining Framework in Drugs Cases).
      • That DOJ Department Circular No. 018, issued 2022, remedies the issue of lacking prosecution consent in plea bargaining cases.

Issues:

  • Whether the Court of Appeals erred in ruling that the RTC committed grave abuse of discretion by approving Bason’s plea bargaining proposal over the objection of the prosecution.
  • Whether DOJ Department Circular No. 018 cured the issue on the lack of consent in plea bargaining cases.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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