Case Summary (G.R. No. 226679)
Key Dates
– March 21, 2016: Alleged possession of shabu.
– June 15, 2016: Estipona’s motion to enter plea bargaining.
– July 12, 2016: RTC order denying the motion.
– July 26, 2016: Denial of motion for reconsideration.
– August 15, 2017: Supreme Court decision.
Applicable Law
– 1987 Philippine Constitution, Article VIII, Section 5(5) (exclusive rule-making power of the Supreme Court).
– Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002), Section 23 (absolute ban on plea bargaining).
– Supreme Court Rules on Criminal Procedure (particularly Rules 116 and 118 regarding plea to lesser offenses and pre-trial conference).
Factual Background
Estipona was charged under Section 11, Article II of RA 9165 (possession of a dangerous drug). He initially pleaded not guilty but filed a motion to withdraw that plea and instead plead guilty to a lesser offense (possession of paraphernalia under Section 12, Article II) to avail himself of rehabilitation provisions.
Motion for Plea Bargaining
Estipona argued Section 23 of RA 9165—which categorically bars plea bargaining for all drug offenses—violates (1) the law’s rehabilitative intent (Section 2(3) of RA 9165), (2) the Supreme Court’s rule-making authority under the 1987 Constitution, and (3) the separation of powers doctrine.
Opposition and RTC Ruling
The prosecution opposed based on the express mandate of Section 23. RTC Branch 3 held that plea bargaining is a procedural rule found in Rules of Court (Rule 118) and that Section 23 effectively suspends Rule 118, thereby encroaching on the Supreme Court’s exclusive rule-making power. The court nonetheless declined to declare Section 23 unconstitutional, citing prudential restraint.
Issues Presented
I. Whether Section 23 of RA 9165 violates the equal protection clause.
II. Whether it encroaches on the Supreme Court’s rule-making power.
III. Whether the RTC gravely abused its discretion by refusing to declare Section 23 unconstitutional.
Supreme Court Analysis – Procedural Posture
The Court exercised its authority to suspend procedural rules in service of substantial justice and transcendental public interest (urgent need to protect accused rights amid the drug crisis). Technical defects were set aside to address the constitutional question.
Supreme Court Analysis – Exclusive Rule-Making Power
Article VIII, Section 5(5) vests in the Supreme Court alone the power to promulgate procedural rules; Congress may no longer amend or override them. Historical evolution confirms the framers’ intent to bolster judicial independence by removing congressional concurrence in procedural matters. Precedent has struck down statutes that effectively alter Rules of Court.
Plea Bargaining as a Procedural Rule
Plea bargaining is embedded in Rules 116 and 118 as a means to streamline criminal proceedings, conserve judicial resources, and facilitate rehabilitative outcomes. It neither creates nor abolishes substantive rights but regulates how existing rights are enforced. Its discretionary nature protects the integrity of prosecutions and ensures that concessions arise from mu
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