Case Digest (G.R. No. 98368) Core Legal Reasoning Model
Facts:
The case involves respondents Edgar Majingcar y Yabut and Christopher Ryan Llaguno y Matos, who were charged with violations of Sections 5 and 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002). On or about October 5, 2016, in Naga City, both accused were charged with selling and possessing methamphetamine hydrochloride ("shabu") respectively. Majingcar was charged with illegal sale, and Llaguno was charged with illegal possession. Both pleaded not guilty initially. Subsequently, both respondents proposed to plead guilty to the lesser offense under Section 12 of RA 9165 pursuant to A.M. No. 18-03-16-SC, the Supreme Court's plea bargaining framework for drug cases. The prosecution only agreed to the plea bargain for Criminal Case No. 2016-0775 but objected to that proposed for Criminal Case No. 2016-0774.
The trial court nonetheless approved both plea bargains on August 6, 2018, and declared certain DOJ Circulars and Regional Prosec
Case Digest (G.R. No. 98368) Expanded Legal Reasoning Model
Facts:
- Parties and Charges
- Respondents Edgar Majingcar y Yabut and Christopher Ryan Llaguno y Matos were charged with violations of Sections 5 and 11, Article II of Republic Act No. 9165 (RA 9165), involving illegal sale and possession of dangerous drugs.
- Criminal Case No. 2016-0774 charged Majingcar and Llaguno with the sale of one sachet containing 0.056 gram of methamphetamine hydrochloride ("shabu") to a poseur buyer on or about October 5, 2016, in Naga City.
- Criminal Case No. 2016-0775 charged them with possession of nine sachets containing a total of 0.309 grams of methamphetamine hydrochloride on the same date and place.
- Trial Proceedings and Plea Bargaining
- Upon arraignment, respondents pleaded not guilty to both charges.
- Respondents later submitted proposals to plead guilty to a lesser offense—violation of Section 12, Article II of RA 9165—under the plea bargaining framework adopted in A.M. No. 18-03-16-SC.
- The prosecution counter-proposed that respondents plead guilty to Section 5 with penalty under paragraph 3, Section 11 of RA 9165 in Criminal Case No. 2016-0774, and raised no objection to respondents' plea bargaining proposal in Criminal Case No. 2016-0775.
- Trial Court Resolution
- On August 6, 2018, the Regional Trial Court (RTC) allowed respondents’ plea bargaining proposals and declared DOJ Circular Nos. 061 (Nov 21, 2017), 027 (June 26, 2018), and RPO Order No. 027-E-18 (May 17, 2018) unconstitutional for infringing upon the Supreme Court’s rule-making power.
- The prosecution’s motion for reconsideration was denied on September 1, 2018.
- Respondents were re-arraigned on September 5, 2018, and pleaded guilty as per the approved plea bargains.
- On September 18, 2018, the trial court rendered judgment finding the respondents guilty of violation of Section 12, Article II of RA 9165 in both cases, sentencing them to indeterminate imprisonment terms and fines.
- Court of Appeals Proceedings
- The People filed a petition for certiorari before the Court of Appeals (CA) challenging the plea bargaining resolution and judgment.
- The CA dismissed the petition on two grounds: late filing beyond the 60-day reglementary period and lack of merit.
- The CA upheld (a) the constitutionality of the plea bargaining framework under A.M. No. 18-03-16-SC and the invalidity of the cited DOJ circulars, and (b) the trial court’s approval of respondents’ plea bargaining despite the prosecution’s objection in Criminal Case No. 2016-0775 because the prosecution did not object to that particular plea.
- The People’s motion for reconsideration was denied on September 24, 2019.
- Present Petition Before the Supreme Court
- The People contest (a) the CA’s ruling on the untimeliness of their petition; (b) the approval of respondents’ plea bargaining in Criminal Case No. 2016-0774 without the prosecution’s consent; and (c) the trial court’s declaration of unconstitutionality of the DOJ circulars without proper issues raised.
- Respondents opposed, arguing (a) finality of RTC judgment and improper remedy; (b) plea bargaining discretion resides with the judge; (c) the necessity of the DOJ circulars’ constitutionality resolution; and (d) violation of their right against double jeopardy if the petition is granted.
Issues:
- Whether the Court of Appeals erred in declaring that the petition for certiorari was filed out of time.
- Whether the Court of Appeals erred in affirming the approval of respondents’ plea bargaining plea to a lesser offense without the consent of the prosecution in Criminal Case No. 2016-0774.
- Whether the Court of Appeals erred in affirming the trial court’s declaration of unconstitutionality of DOJ Circular Nos. 027 and 061 and RPO Order No. 027-E-18.
- Whether the People’s petition against the final judgment violates respondents’ right against double jeopardy.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)