G.R. No. 259728 - People vs. Reyes y Cabornay

The People of the Philippines (petitioner), through the Office of the Solicitor General, filed a Petition for Review on Certiorari against Darwin Reyes y Cabornay (respondent).
The petition assailed the Decision dated June 28, 2021 and Resolution dated March 10, 2022 of the Court of Appeals (CA) in CA-G.R. SP No. 164335.
The CA annulled and set aside the November 26, 2019 Order of the Regional Trial Court (RTC) of Balanga City, Bataan, Branch 1, which denied respondent’s motion for reconsideration and disqualified him from applying for probation.

Two separate Informations charged respondent for violation of Sections 5 and 11, Article II of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002):

Criminal Case No. 20215 - Illegal possession of 0.118 gram of methamphetamine hydrochloride ("shabu").
Criminal Case No. 20216 - Illegal sale/distribution of 0.066 gram of shabu.

On November 15, 2019, during trial, respondent moved to plead guilty to a lesser offense (violation of Section 12, Article II of RA 9165 - illegal possession of drug paraphernalia) for Criminal Case No. 20216.
The prosecution objected on the ground that the plea did not comply with DOJ Circular No. 027.
The RTC nonetheless granted the motion, convicted respondent of the lesser offense, sentenced him to 6 months and 1 day to 3 years imprisonment, and imposed a fine of Php10,000, with subsidiary imprisonment in case of insolvency.
The RTC required drug testing and possible rehabilitation conditional on test results.
The RTC declared respondent ineligible to apply for probation.
Respondent’s motion for reconsideration to contest the probation disqualification was denied on November 26, 2019.

Respondent filed a Petition for Certiorari before the CA.
The CA granted the petition, annulled the RTC’s November 26, 2019 Order, and deleted the probation ineligibility portion of the November 15, 2019 Order.
The CA allowed respondent 15 days from notice to file an application for probation.
The prosecution’s Motion for Reconsideration was denied by the CA on March 10, 2022.

The People filed the instant petition to challenge the CA’s ruling that respondent is eligible to apply for probation.
The People argued that the plea bargain entered by respondent was invalid as it did not conform with DOJ Circular No. 027 conditions, rendering the conviction void and probation inapplicable.

Whether the Court of Appeals erred in ruling that respondent is eligible to apply for probation despite originally being charged with illegal sale of dangerous drugs under Section 5, Article II of RA 9165, but ultimately convicted by plea bargain of a lesser offense under Section 12, Article II of the same law.
Whether the plea bargaining conducted was valid, considering the form and compliance with DOJ Circular No. 027 as amended and the Court’s Plea Bargaining Framework.
Whether the RTC correctly disqualified respondent from seeking probation.