Case Summary (G.R. No. 199455)
Facts and Antecedent Proceedings
The petitioners faced charges for violating Section 13, in relation to Section 11 of Article II of Republic Act No. 9165, specifically for possessing a sachet of methamphetamine during a social gathering in Parañaque City. After initially pleading "not guilty," the petitioners sought to withdraw this plea on July 5, 2018, arguing that plea bargaining should apply to their case given the recent rulings and supportive frameworks, particularly citing Administrative Matter No. 18-03-16-SC as well as the Supreme Court's ruling in Estipona v. Hon. Lobrigo. Following the grant of their motion by the RTC to withdraw the plea on August 15, 2018, the petitioners were allowed to plead guilty to a lesser offense under Section 11, Paragraph 3 of R.A. No. 9165, which carries harsher penalties than suggested by the provisions of A.M. No. 18-03-16-SC.
Key Issues
- Constitutionality of DOJ Circular No. 027 and its encroachment upon the Supreme Court's rule-making power.
- Petitioners' entitlement to plea bargain under A.M. No. 18-03-16-SC.
- Potential violation of constitutional rights regarding drug dependency assessments mandated by the DOJ Circular.
- Alleged grave abuse of discretion by the RTC in permitting petitioners to plead guilty to a section with harsher penalties.
Petitioners' Arguments
The petitioners assert that the case necessitates immediate judicial intervention due to allegations of the DOJ Circular overstepping its bounds and infringing upon rights related to self-incrimination and privacy. They argue that the Circular illegitimately expands the scope of plea bargaining beyond what was established in A.M. No. 18-03-16-SC and creates punitive measures that effectively raise the penalties. They contend that their case, involving possession of a small amount of drugs, should allow for a plea bargain to a lesser, more appropriate offense.
Respondents' Arguments
The Office of the Solicitor General (OSG) counters by stating that the RTC acted correctly by adhering to DOJ Circular No. 027, which permits plea bargaining for the charge under Section 13 to the lesser offense defined in Section 11, Paragraph 3. The OSG maintains that the DOJ has the authority to establish rules and guidelines for plea bargaining without infringing on the Supreme Court's rule-making power. Furthermore, they argue that the petitioners' assertions regarding constitutional violations are unfounded given the nature of applicable drug dependency assessments, which are integral to the plea bargaining process.
Court's Ruling
The Court endorsed the use of Certiorari as appropriate for reviewing the RTC's interlocutory orders, which do not offer an immediate right to appeal. The Court found that the RTC's action constituted an interlocutory order since further proceedings were required to reach a final judgment. The Court reiterated the guidelines outlined in Montierro for plea bargaining, emphasizing that plea agreements require proper evaluation of both the prosecution's evidence and the petitioner
...continue readingCase Syllabus (G.R. No. 199455)
Case Overview
- Case Reference: G.R. No. 242722
- Date of Decision: October 10, 2022
- Petitioners: Carlos Cereza, Roger Estolonillo, Raymundo Lopez, Yolanda Pascual, Merly Ann Montes, May Ann Villa
- Respondents: Hon. Danilo V. Suarez (Presiding Judge, RTC of ParaAque City, Branch 259), People of the Philippines
Nature of the Petition
- The case involves a Petition for Certiorari under Rule 65, challenging two orders from the Regional Trial Court (RTC) of ParaAque City.
- The first order (August 15, 2018) allowed the petitioners to withdraw their plea of "NOT GUILTY" and enter a plea for a lesser offense under Republic Act No. 9165.
- The second order (September 11, 2018) denied the petitioners' partial motion for reconsideration.
Facts and Antecedent Proceedings
- Petitioners were charged with violating Section 13 in relation to Section 11 of Article II of R.A. No. 9165, involving the possession of dangerous drugs during a social gathering.
- They were arraigned on November 6, 2015, entering a plea of "NOT GUILTY."
- On July 5, 2018, they filed a motion to withdraw their plea based on the ruling in Estipona v. Hon. Lobrigo, arguing for plea bargaining.
- The RTC granted their motion, allowing a plea to a lesser offense under Section 11, Paragraph 3 of R.A. No. 9165.
Legal Issues Presented
- I. Whether DOJ Circular No. 027 is unconstitutional for encroaching upon the rule-making power of the Supreme Court.
- II. Whether the petitioners are entitled to plea