Case Summary (G.R. No. 258893)
Charges Against the Petitioner
Raul faced two separate charges:
- Criminal Case No. 2017-24487: Involves the illegal sale of drugs, where it was alleged that on May 29, 2017, in the City of Dumaguete, Raul sold a heat-sealed plastic sachet containing 0.04 gram of shabu to a police poseur buyer.
- Criminal Case No. 2017-24488: Involves the illegal possession of drugs, where he was found with eleven sachets totaling 0.91 gram of shabu.
Initial Court Proceedings
Upon arraignment, Raul pleaded not guilty to both charges and subsequently filed a Motion for Plea Bargaining, expressing his willingness to plead guilty to a lesser offense under Section 12 of Republic Act No. 9165, which relates to illegal possession and carries a lighter penalty. The prosecution agreed to this plea for the possession charge but objected to the plea in relation to the sale, citing DOJ Circular No. 027 which prohibited such plea bargains for illegal sale of drugs.
Ruling of the Regional Trial Court
The RTC granted Raul's plea bargain through an Order dated August 9, 2018, asserting that it complied with the relevant guidelines. The court declared him guilty of a violation of Section 12 under both charges, imposing sentences that included penalties, fines, and stipulations for drug rehabilitation if he tested positive for drug use. The prosecution filed for reconsideration, arguing that the plea bargain for the sale charge should not have been accepted, but the motion was denied.
Ruling of the Court of Appeals
The CA later reversed the RTC's decision through a ruling that emphasized the necessity of the prosecution's consent in plea bargaining agreements. The CA criticized the RTC's decision to grant Raul’s plea bargain for the sale of drugs, contending that the prosecution's objection invalidated the plea agreement. Consequently, the CA directed the RTC to proceed with Raul's trial on the original charge of illegal sale of dangerous drugs.
Issue Before the Supreme Court
The primary issue raised for resolution was whether the RTC had gravely abused its discretion by approving Raul's plea bargain despite the prosecution’s objection, particularly considering DOJ Circular No. 027's stipulations regarding plea bargaining in illegal sale cases.
Supreme Court's Ruling
The Supreme Court granted Raul’s petition, observing that DOJ Circular No. 27 had been revoked by DOJ Circular No. 18, which realigned provisions to correspond with the Court's Plea Bargaining Framework for drugs. This effectively rendered the prosecution’s objection moot. The Court reiterated the guidelines from People v. Montierro and confirmed that the RTC's acceptance of Raul’s plea bargain was not a grave abuse of discretion. The quantity of drugs involved justified the registered plea to a lesser charge under Section 12, thereby allowing the plea bargain process to follow the Court's framework.
Remand to the Regional Trial Court
The Court remanded the two criminal cases to the RTC for further evaluation focused on assessing
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Facts of the Case
- Raul Domen y Aurellano (the accused) was charged in two separate Criminal Cases No. 2017-24487 and 2017-24488 before the Regional Trial Court (RTC), Branch 30, Dumaguete City, Negros Oriental.
- Criminal Case No. 2017-24487: Illegal Sale of Dangerous Drugs. Raul was accused of selling one heat sealed sachet containing 0.04 gram of Methamphetamine Hydrochloride (shabu) to a police poseur buyer.
- Criminal Case No. 2017-24488: Illegal Possession of Dangerous Drugs. Raul was found in possession of eleven heat sealed plastic sachets containing a total weight of 0.91 gram of Methamphetamine Hydrochloride.
- Raul was also found positive for the use of Methamphetamine as evidenced by Chemistry Report No. DT-164-17.
- Upon arraignment, Raul pleaded not guilty to both charges.
- Subsequently, Raul filed a Motion for Plea Bargaining, offering to plead guilty to a lesser offense under Section 12 of Republic Act No. 9165, punishable by 6 months and 1 day to 4 years imprisonment and a fine ranging from PHP 10,000 to PHP 50,000.
Procedural History
- The prosecution accepted the plea bargaining offer for the illegal possession charge but rejected the plea for the illegal sale charge, citing DOJ Circular No. 027 which prohibits plea bargaining in illegal sale cases.
- The RTC, despite the prosecution's objection, granted Raul's Motion for Plea Bargaining, convicting him of two counts of violating Section 12 of RA 9165, with corresponding penalties and fines.
- The prosecution sought reconsideration which the RTC denied.
- The prosecution filed a Petition for Certiorari, Prohibition, and Mandamus with the Court of Appeals (CA).
- The CA granted the petition, set aside the RTC's orders and judgment in the illegal sale case, and ordered trial to proceed for the original charge.
- Raul sought reconsideration from CA, which was denied, prompting the filing of a petition before the Supreme Court.
Issue
- Whether the RTC grievously abused its discretion in approving Raul’s plea bargaining in the illegal sale case despite the prosecution’s objection based on DOJ Circular No. 027 which prohibits plea bargaining for illegal sale of dangerous drugs.
Ruling of the Supreme Court
- The Supreme Court took judicial notice that DOJ Circular N