RODULFO FERRAREN AQUINO A.K.A. "YOYON", PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.
- G.R. Number: G.R. No. 259094
- Promulgated: 2025-01-28
- Ponente: DIMAAMPAO, J.
Doctrine
## Facts of the Case Rodulfo Ferraren Aquino a.k.a. "Yoyon" (Aquino) was charged with illegal sale and possession of dangerous drugs under Republic Act No. 9165. He initially pled not guilty, but later filed a Motion for Plea Bargaining, seeking to plead guilty to the lesser offense of violation of Section 12 of Republic Act No. 9165 (illegal possession of drug paraphernalia). The prosecution consented to the plea bargain for the illegal possession charge but objected to it for the illegal sale charge, citing DOJ Department Circular No. 027 which did not allow plea bargaining for Section 5 violations to Section 12. Despite the prosecution's objection regarding the illegal sale charge, the Regional Trial Court (RTC) granted Aquino's motion, ruling that the plea bargain was in accordance with the Supreme Court's Plea Bargaining Framework in Drug Cases, considering the small quantities of shabu involved. Aquino then pled guilty to two charges of violation of Section 12. The RTC rendered a Joint Judgment finding him guilty of illegal possession of drug paraphernalia. The prosecution moved for reconsideration, which the RTC denied. The People of the Philippines, through the Office of the Solicitor General, filed a petition for certiorari with the Court of Appeals (CA), which annulled the RTC's rulings, stressing the necessity of the prosecution's consent. Aquino appealed to the Supreme Court. ## Issues 1. Did the Court of Appeals err in annulling the RTC's approval of Aquino's plea bargain for the illegal sale charge under the belief that the prosecution's consent was absolutely necessary, even when the objection was based solely on an internal DOJ circular contradicting the Supreme Court's plea bargaining framework? 2. Should cases where the trial court did not make explicit findings on the strength of evidence or the character of the accused, but where the prosecution only raised specific objections, be mandatorily remanded for further findings? ## Decision / Rationale **Issue 1:** The Court of Appeals erred in annulling the RTC's approval of Aquino's plea bargain. The Supreme Court, citing and applying **People v. Montierro**, held that courts may overrule the prosecution's objection to plea bargaining offers in drug cases if the objection is based solely on the ground that the accused's proposal is inconsistent with internal rules or guidelines of the Department of Justice (DOJ), but is in accordance with the plea bargaining framework issued by the Court. The **Montierro** ruling affirmed the Court's exclusive rule-making power and clarified that the authority of the court over plea bargaining is primarily circumscribed by the Court-issued framework. The Court noted that **DOJ Department Circular No. 027**, which the prosecution relied upon for its objection, was later revoked and replaced by **DOJ Department Circular No. 18**. The latter circular now allows an accused to plead guilty to the lesser offense of illegal possession of drug paraphernalia under Section 12 of Republic Act No. 9165 from an original charge of illegal sale of dangerous drugs under Section 5. Given this, and in line with the **Montierro** guidelines, the RTC's decision to approve Aquino's plea bargaining proposal in Criminal Case No. 2019-26185 was correct. Therefore, the CA's annulment of these rulings was erroneous, and the RTC's May 30, 2019 Order and Joint Judgment are reinstated. **Issue 2:** No, cases where the prosecution's objection was based only on specific grounds should not be mandatorily remanded for additional findings on unraised grounds. The Court observed that mandating remands to determine grounds not initially raised by the prosecution, such as the strength of the evidence or characteristics of the accused (recidivism, habitual offender, etc.), causes undue delay, defeats the purpose of plea bargaining, and effectively forces the court to act as the prosecutor. To address this, the Court promulgated supplementary guidelines based on the…
Facts
Petitioner Rodulfo Aquino was charged with illegal sale and possession of dangerous drugs. He moved to plead guilty to the lesser offense of illegal possession of drug paraphernalia for both charges. The prosecution objected to the plea bargain for the illegal sale charge, based on a Department of Justice (DOJ) circular, but the Regional Trial Court (RTC) granted the motion over the objection. The Court of Appeals (CA) annulled the RTC's decision, ruling that the prosecutor's consent is mandatory.
Issues
Whether a trial court can grant an accused's motion to plea bargain to a lesser offense in a drug case if the prosecution's objection is based solely on an internal Department of Justice (DOJ) circular that contradicts the Supreme Court's plea bargaining framework.
Ruling
The Supreme Court granted the petition, reversing the Court of Appeals. The Court upheld the RTC's decision, applying the doctrine in People v. Montierro, which allows courts to overrule the prosecution's objection if it is based only on DOJ guidelines that are contrary to the Court's own plea bargaining framework. The Court also introduced new guidelines, stating that any grounds for objection not raised by the prosecution in its opposition to a plea bargain are deemed waived, thereby preventing unnecessary remands and delays. The RTC's judgment convicting the petitioner of the lesser offense was reinstated.
Keywords
Republic Act No. 9165 Section 12, Republic Act No. 9165 Section 5, Rule 45 of the Rules of Court, Rule 65 of the Rules of Court, Rule 116 Section 2 of the Rules of Court, DOJ Department Circular No. 027, DOJ Department Circular No. 18, A.M. No. 18-03-16-SC, Montierro guidelines, Sayre v. Judge Xenos doctrine, Bason Guidelines, Aquino Guidelines, Omnibus Motion Rule, Plea Bargaining in Dangerous Drugs Cases, Illegal Sale of Dangerous Drugs, Illegal Possession of Dangerous Drugs, Illegal Possession of Drug Paraphernalia, Petition for Review on Certiorari, Certiorari, Grave Abuse of Discretion