Quiqui v. People
REITERATIONFacts
The Antecedents: The case originated from an Information charging Teresito Radonis Quiqui with Illegal Sale of Dangerous Drugs under Section 5, Article II of Republic Act No. 9165, for allegedly selling 0.10 gram of methamphetamine hydrochloride, commonly known as "shabu." Upon arraignment, Quiqui pleaded not guilty to the charge. Procedural History: During the trial, Quiqui filed a motion to enter into a plea bargain, proposing to plead guilty to the lesser offense of Illegal Possession of Drug Paraphernalia under Section 12, Article II of RA 9165, citing A.M. No. 18-03-16-SC. The prosecution opposed this, citing Department of Justice (DOJ) Department Circular No. 027, which suggested a plea bargain to Section 11, Article II of RA 9165 for similar quantities. The Regional Trial Court (RTC) approved the plea bargain, finding it in accord with the law and the quantity of drugs involved. Quiqui was re-arraigned and pleaded guilty to the lesser offense. The RTC subsequently rendered judgment finding him guilty of Section 12, Article II of RA 9165 and imposing a sentence. The People, through the Office of the Solicitor General (OSG), filed a Petition for Certiorari before the Court of Appeals (CA), arguing grave abuse of discretion by the RTC. The CA reversed the RTC's orders and judgment, declaring them void and ordering the RTC to proceed with the original case. The Petition: Quiqui filed a Petition for Review on certiorari under Rule 45 of the Rules of Court, assailing the CA's Decision and Resolution. He argues that the CA erred in declaring his plea-bargaining proposal void. The Supreme Court took judicial notice of DOJ Department Circular No. 018, which revised DOJ Circular No. 027 and aligned with A.M. No. 18-03-16-SC, allowing plea bargains to Section 12 for small quantities of shabu. The Court emphasized its exclusive rule-making power over procedural matters, including plea bargaining, and reviewed the guidelines for plea bargaining in drug cases. Ultimately, the Court found that the RTC properly exercised its discretion in granting the plea bargain, considering the prosecution's objection was based solely on a DOJ circular inconsistent with the Court's framework and that the RTC found no strong evidence of guilt or other grounds to deny the plea bargain. The Supreme Court reversed the CA's decision, reinstating the RTC's orders and judgment.
Issue(s)
Whether the Court of Appeals seriously erred when it declared that the petitioner's plea-bargaining proposal is void. Whether the RTC gravely abused its discretion in approving the plea bargain over the prosecution's opposition.
Ruling
The Supreme Court granted the petition, reversed and set aside the assailed CA Decision and Resolution, and reinstated the RTC Orders. Petitioner Teresito Radonis Quiqui was found guilty beyond reasonable doubt of Illegal Possession of Equipment, Instrument, Apparatus and Other Paraphernalia for Dangerous Drugs under Section 12, Article II of RA 9165, and sentenced to two (2) years as minimum to four (4) years as maximum, and to pay a fine of Fifty Thousand Pesos (₱50,000.00). The Decision is immediately executory.
Ratio Decidendi
On the issue of whether the CA erred in declaring the plea-bargaining proposal void: The Court ruled that the CA erred. It took judicial notice of DOJ Department Circular No. 018, which revoked DOJ Circular No. 027 and aligned with A.M. No. 18-03-16-SC, allowing plea bargains to Section 12 for shabu quantities of 0.01 to 0.99 grams. The petitioner's case, involving 0.10 gram of shabu, clearly fell within this permissible plea bargain. The Court emphasized that plea bargaining is a rule of procedure falling within the Court's exclusive rule-making power under Article VIII, Section 5(5) of the Constitution. While DOJ Circular No. 027 was previously upheld in Sayre v. Xenos, it was clarified that such circulars serve only as internal guidelines for prosecutors and do not repeal or modify the Court's framework. The RTC retains sound discretion to approve or deny plea bargains. On the RTC's discretion and the prosecution's opposition: The Court found that the RTC did not gravely abuse its discretion. Unlike in People v. Reafor, where the RTC immediately granted the plea bargain despite the prosecution's opposition without resolving the grounds, the RTC in this case considered the submissions of both parties. The prosecution's opposition was based solely on its inconsistency with DOJ Circular No. 027, which the Court clarified is not binding on the RTC's discretion. The RTC also conducted an independent determination of the evidence, finding that the prosecution failed to establish strong evidence of guilt or any grounds to deny the plea bargain, such as recidivism or habitual offending, and even noted a potential issue with the chain of custody. The Court reiterated that the acceptance of a plea to a lesser offense is not a matter of right but is addressed to the sound discretion of the trial court, which must be exercised judiciously. The Court applied the guidelines established in People v. Montierro, Baldadera v. People, and Re: Letter of the Philippine Judges Association. These guidelines underscore that plea bargaining requires a written motion, the lesser offense must be necessarily included, and the court must exercise sound discretion. Crucially, the court may overrule the prosecution's objection if it is based solely on internal DOJ rules inconsistent with the Court's framework, provided there are no valid grounds like strong evidence of guilt. The RTC's decision to allow the plea bargain was consistent with these guidelines, as the prosecution's objection lacked merit beyond the internal circular, and the RTC found no strong evidence of guilt.
Main Doctrine
The Supreme Court's rule-making power under Article VIII, Section 5(5) of the Constitution is exclusive, and while DOJ circulars may serve as internal guidelines for prosecutors, they cannot repeal, alter, or modify the Court's procedural rules on plea bargaining. Trial courts retain sound discretion to grant or deny plea bargain proposals, even over the prosecution's objection, provided the objection is not based on strong evidence of guilt or other valid grounds, and the proposal conforms to the Court's plea bargaining framework.