AQUINO V. PEOPLE [G.R. No. 259094, January 28, 2025]

 CASE DIGEST

AQUINO V. PEOPLE

[G.R. No. 259094, January 28, 2025]

EN BANC, Dimaampao, J.

 

Plea Bargaining in Drug Cases; Prosecutorial Objection; Rule-Making Power of the Supreme Court; Waiver of Grounds for Objection. 

A trial court may overrule the prosecution's objection to a plea bargaining proposal in drug cases when the objection is based solely on the Department of Justice's internal guidelines that are inconsistent with the Supreme Court's Plea Bargaining Framework. The Supreme Court's constitutional rule-making power prevails over executive issuances governing court procedure. Moreover, Prosecutors must raise all their objections when an accused offers to plead guilty to a lesser crime. When the prosecution raises only specific grounds in opposing a plea bargain, all other available grounds not invoked are deemed waived, consistent with the principle behind the Omnibus Motion Rule. 

 

Rodulfo Ferraren Aquino, also known as "Yoyon," was charged before the Regional Trial Court (RTC) of Dumaguete City with two separate offenses under Republic Act No. 9165: (1) Illegal Sale of Dangerous Drugs under Section 5 for selling one sachet containing 0.18 gram of shabu; and (2) Illegal Possession of Dangerous Drugs under Section 11 for possessing thirteen sachets of shabu weighing an aggregate of 1.84 grams. Upon arraignment, Aquino initially entered pleas of not guilty. 

Before trial commenced, Aquino filed a Motion for Plea Bargaining pursuant to A.M. No. 18-03-16-SC (Plea Bargaining Framework in Drug Cases), seeking to plead guilty to the lesser offense of Illegal Possession of Drug Paraphernalia under Section 12 of Republic Act No. 9165 in both criminal cases. The prosecution agreed to the plea bargain only with respect to the illegal possession case but vigorously objected insofar as the illegal sale case was concerned. It argued that DOJ Department Circular No. 027 prohibited plea bargaining from a charge under Section 5 to the lesser offense under Section 12. 

The RTC overruled the prosecution's objection, granted Aquino's motion, allowed him to re-arraign on the lesser offense, accepted his guilty plea, and convicted him of two counts of violation of Section 12 of Republic Act No. 9165. The prosecution's motion for reconsideration was denied. Thereafter, the Office of the Solicitor General filed a Petition for Certiorari before the Court of Appeals (CA), alleging that the RTC gravely abused its discretion in approving the plea bargain without the prosecution's consent. The CA granted the petition, annulled the RTC's Order and Joint Judgment, and ruled that plea bargaining required the consent of both the prosecutor and the offended party under Rule 116 of the Rules of Court. Aquino elevated the case to the Supreme Court. 

 

Issue No. 1: Whether or not the trial court may approve a plea bargaining proposal despite the prosecution's objection based solely on DOJ Department Circular No. 027.

YES. The Supreme Court ruled that the RTC correctly approved Aquino's plea bargaining proposal. During the pendency of the case, the Court promulgated People v. Montierro, which modified the earlier ruling in Sayre v. Xenos. Montierro categorically held that courts are not bound by DOJ internal rules governing plea bargaining. The Supreme Court possesses the exclusive constitutional authority to promulgate rules concerning pleading, practice, and procedure before the courts. 

Accordingly, when the prosecution's objection merely rests on a DOJ circular inconsistent with the Supreme Court's Plea Bargaining Framework, the trial court may validly overrule such objection. Since the prosecution in Aquino objected solely because DOJ Department Circular No. 027 allegedly prohibited plea bargaining for Section 5 offenses, the RTC correctly disregarded the objection and approved the plea bargain.

 

Issue No. 2: Whether or not the Court of Appeals correctly annulled the RTC's approval of the plea bargaining agreement.

NO. The Court held that the CA erred in relying on the earlier doctrine in Sayre, which had already been modified by People v. Montierro. Montierro recognized that judicial discretion over plea bargaining cannot be subordinated to executive issuances. The CA therefore incorrectly concluded that the prosecutor's consent was indispensable where the only objection was the inconsistency of the proposed plea bargain with DOJ guidelines. Consequently, the RTC's Order approving the plea bargain and its Joint Judgment convicting Aquino of the lesser offense under Section 12 should be reinstated. 

 

Issue No. 3: Whether or not the prosecution waives other possible objections by raising only one ground against the accused's motion for plea bargaining.

YES.  The Supreme Court introduced a new procedural doctrine patterned after the Omnibus Motion Rule. The Court held that where the prosecution opposes a plea bargaining proposal but relies only on one or several specific grounds, all other available grounds not asserted are deemed waived. The prosecution cannot later invoke new objections that it failed to raise before the trial court. 

This rule prevents unnecessary remands and promotes the objectives of plea bargaining—speed, economy, efficiency, and finality in criminal proceedings. It also respects the Executive's prosecutorial discretion because the prosecutor alone decides what objections to raise, while ensuring that omitted objections are treated as abandoned. 

 

Issue No. 4: Whether or not the Supreme Court laid down new comprehensive guidelines governing plea bargaining in drug cases.

YES. Recognizing recurring confusion among trial courts, the Supreme Court supplemented the guidelines established in People v. Montierro.

Among the significant additions are:

• objections not raised by the prosecution are deemed waived;
• trial courts must resolve every ground specifically raised by the prosecution;
• appellate courts shall remand cases only when necessary to resolve unresolved objections;
• appellate courts should reinstate the correct judgment where the trial court properly applied the rules; and
• where both the trial court and appellate court erred, the Supreme Court may direct the trial court to allow plea bargaining and render judgment accordingly.

These comprehensive guidelines are intended to provide uniform standards for all courts handling plea bargaining under Republic Act No. 9165.

 

DISPOSITION

The Petition was GRANTED.

The Supreme Court REVERSED and SET ASIDE the Decision and Resolution of the Court of Appeals. It REINSTATED the RTC's May 30, 2019 Joint Judgment finding Rodulfo Ferraren Aquino guilty of the lesser offense of Illegal Possession of Drug Paraphernalia under Section 12 of Republic Act No. 9165 in both criminal cases. The Court likewise adopted supplemental guidelines governing plea bargaining in dangerous drug cases, particularly on the waiver of unraised prosecutorial objections and the proper disposition of such motions by trial and appellate courts.



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