People v. Sayre
REITERATIONFacts
The Antecedents: Nurullaje Sayre y Malampad (@ "Inol") was charged with violations of Sections 5, 11, and 12, Article II of Republic Act No. (R.A.) 9165, in three separate Informations. Specifically, he was charged with illegal sale of 0.1029 grams of Methylamphetamine Hydrochloride (Shabu) (Crim. Case No. CRC 416-2017), illegal possession of 0.870, 0.6543, 0.0545, and 0.0531 grams of Shabu (Crim. Case No. CRC 417-2017), and possession of a tooter, an equipment for smoking dangerous drugs (Crim. Case No. CRC 418-2017). Procedural History: Sayre filed a Motion to Plea Bargain, proposing to plead guilty to a lesser offense under Section 12 of R.A. 9165 for the charges of illegal sale and possession, which carries a penalty of imprisonment from six (6) months and one (1) day to four (4) years, and compulsory rehabilitation. Subsequently, pursuant to OCA Circular No. 90-2018 adopting the Plea Bargaining Framework in Drug Cases, Sayre filed a Motion for Approval of Plea-Bargaining Proposal with Modification. He proposed to plead guilty to Section 12 for the charges under Sections 5 and 11, and to Section 15 for the charge under Section 12, with a modified penalty of undergoing counseling at a rehabilitation center, as he tested negative for drug use. The Regional Trial Court (RTC) of Panabo City, Branch 34, denied Sayre's Motion to Plea Bargain and subsequently denied his Motion for Reconsideration. The prosecution, through the City Prosecutor, filed a Comment and Counter-Proposal in accordance with DOJ Circular No. 27. The Petition: Sayre filed a Petition for Certiorari and Prohibition assailing the RTC's Orders denying his plea bargain proposal.
Issue(s)
Whether the Regional Trial Court committed grave abuse of discretion amounting to lack or excess of jurisdiction in denying the Motion to Plea Bargain filed by the petitioner. Whether the plea bargaining proposal of the petitioner, as modified, should be approved in light of the Supreme Court's Plea Bargaining Framework in Drug Cases.
Ruling
The Petition is GRANTED. The Orders dated December 6, 2018 and January 23, 2019 of the Regional Trial Court of Panabo City, Davao del Norte, Branch 34, in Crim. Case Nos. CRC 416-2017, 417-2017, and 418-2017, are REVERSED and SET ASIDE. The case is REMANDED to the Regional Trial Court for further proceedings consistent with the Plea Bargaining Framework in Drug Cases adopted by this Court.
Ratio Decidendi
On the issue of grave abuse of discretion in denying the plea bargain: The Court held that the RTC committed grave abuse of discretion in denying the petitioner's motion to plea bargain. The Court emphasized that the Plea Bargaining Framework in Drug Cases, adopted through Administrative Matter (A.M.) No. 18-03-16-SC, is a guideline that courts should follow. The framework explicitly allows for plea bargaining in drug cases, providing specific provisions for offenses under Sections 5 and 11 to be pleaded to lesser offenses under Section 12, and for offenses under Section 12 to be pleaded to Section 15. The RTC's outright denial without considering the framework and the specific circumstances of the case, including the petitioner's negative drug dependency test, constituted a grave abuse of discretion. The Court reiterated that the purpose of plea bargaining is to allow an accused to plead guilty to a lesser offense and receive a lighter sentence, thereby promoting judicial economy and avoiding the risks and expenses of trial. The RTC's failure to apply the established framework demonstrated a disregard for the Court's directives and the principles of procedural fairness. The denial was not based on any valid legal grounds that would justify deviating from the established guidelines. On the approval of the plea bargaining proposal: The Court found that the petitioner's modified plea bargaining proposal was in substantial compliance with the Plea Bargaining Framework. The framework allows for the offense of illegal sale of dangerous drugs (Section 5) with a quantity of shabu from 0.1 to 0.99 grams to be plea-bargained under Section 12. Similarly, the offense under Section 11, paragraph 3, with a quantity of shabu from 0.01 to 4.99 grams, can be plea-bargained under Section 12. Furthermore, the offense under Section 12 can be plea-bargained under Section 15, which pertains to the use of dangerous drugs, with penalties ranging from compulsory rehabilitation to counseling. The petitioner's drug dependency test result being negative supported his prayer for a modified penalty of undergoing counseling under Section 15. The Court noted that the prosecution's counter-proposal also acknowledged the possibility of plea bargaining, albeit with different terms. Therefore, the RTC should have considered the proposal in light of the framework and the evidence presented, particularly the drug test result, to determine the appropriate plea bargain.
Main Doctrine
The Supreme Court, in its Resolution dated April 10, 2018 in Administrative Matter No. 18-03-16-SC, adopted a Plea Bargaining Framework for drug cases, which allows plea bargaining for offenses under Sections 5 and 11 of Republic Act No. 9165 to lesser offenses under Section 12, subject to specific conditions and guidelines.