People v. Aurellano
REITERATIONFacts
The Antecedents: Raul Domen y Aurellano was charged in two criminal cases: Criminal Case No. 2017-24487 for illegal sale of 0.04 gram of methamphetamine hydrochloride (shabu), and Criminal Case No. 2017-24488 for illegal possession of 0.91 gram of methamphetamine hydrochloride. He pleaded not guilty to both charges. Subsequently, Raul filed a motion for plea bargaining, offering to plead guilty to a lesser offense under Section 12 of Republic Act No. 9165 (Comprehensive Dangerous Drugs Act of 2002) for both charges. The prosecution agreed to the plea bargain for the possession charge but objected to the sale charge, citing Department of Justice (DOJ) Circular No. 027, which prohibited such plea bargains. Procedural History: The Regional Trial Court (RTC), Branch 30, Dumaguete City, granted Raul's motion for plea bargaining in an Order dated August 9, 2018, and rendered a Joint Judgment on the same date, finding Raul guilty of two counts of violating Section 12 of Republic Act No. 9165. The RTC based its decision on the Court-issued Plea Bargaining Framework in Drugs Cases (A.M. No. 18-03-16-SC), despite the prosecution's objection. The prosecution's motion for reconsideration was denied. The State then filed a Petition for Certiorari, Prohibition, and Mandamus before the Court of Appeals (CA). The CA granted the petition, setting aside the RTC's orders and judgment concerning the plea bargain in the illegal sale case, and directing the RTC to proceed with the trial for the original charge. Raul's motion for reconsideration was denied by the CA. The Petition: Raul Domen y Aurellano filed this petition for review on certiorari under Rule 45 of the Rules of Court, assailing the Decision and Resolution of the Court of Appeals. He argues that the RTC did not gravely abuse its discretion in approving his plea bargain, as it was in accordance with the Court-issued Plea Bargaining Framework in Drugs Cases. The petition highlights that DOJ Circular No. 18, issued subsequent to the CA's decision, revoked DOJ Circular No. 027 and aligned with the Court's framework, effectively withdrawing the prosecution's objection. The core issue presented is whether the RTC gravely abused its discretion in approving the plea bargain despite the prosecution's objection based on a DOJ circular that contradicted the Court's framework.
Issue(s)
Whether the RTC gravely abused its discretion in approving Raul's plea bargain despite the objection of the prosecution based on DOJ Circular No. 027, considering the Court-issued Plea Bargaining Framework in Drugs Cases (A.M. No. 18-03-16-SC), and the net weight of shabu involved. Whether the prosecution's objection to the plea bargain, based solely on DOJ Circular No. 027, could validly prevent the RTC from approving the plea bargain, and the subsequent developments with DOJ Circular No. 18 (2022) necessitate a remand for proper evaluation of Raul's qualification for plea bargaining.
Ruling
The petition is meritorious. The Supreme Court reversed and set aside the Decision and Resolution of the Court of Appeals. The cases were remanded to the court of origin for further evaluation.
Ratio Decidendi
On the issue of grave abuse of discretion and the RTC's approval of the plea bargain: The Supreme Court ruled that the RTC did not gravely abuse its discretion in approving Raul's plea bargain. The RTC's ruling was anchored on the Court-issued Plea Bargaining Framework in Drugs Cases (A.M. No. 18-03-16-SC). The net weight of shabu involved in the illegal sale charge was only 0.04 gram, which, according to the framework, makes a plea of guilty to a violation of Section 12 of RA 9165 acceptable. The Court emphasized that its rule-making power on plea bargaining is exclusive and prevails over conflicting internal rules of the Department of Justice (DOJ). Therefore, the RTC was justified in relying on the Court's framework. On the validity of the prosecution's objection and the subsequent developments and remand: The Supreme Court held that the prosecution's objection, based solely on DOJ Circular No. 027, was not a valid ground to prevent the plea bargain, especially when the proposed bargain conformed to the Court's framework. Citing People v. Montierro, the Court reiterated that judges may overrule a prosecution's objection if it is solely grounded on an executive issuance that contradicts a Court-issued rule on plea bargaining. This is not an intrusion into the executive's authority but a recognition of the Judiciary's constitutional power to promulgate rules. The prosecutor's mandate to prosecute does not preclude the court from exercising its discretion to ensure fairness and reasonableness in plea bargaining. The Court took judicial notice of DOJ Circular No. 18 (2022), which revoked DOJ Circular No. 027 and aligned its provisions with the Court's framework, effectively withdrawing the prosecution's objection. However, the Court found it necessary to remand the cases to the RTC for a proper evaluation of Raul's qualification for plea bargaining. This evaluation must include determining (1) whether the evidence of guilt is strong and (2) whether Raul is a recidivist, habitual offender, known drug addict, troublemaker, has undergone rehabilitation but relapsed, or has been charged many times. Furthermore, if the RTC approves the plea bargain, Raul must undergo a drug dependency assessment as per Bason v. People to ensure treatment or counseling if needed.
Main Doctrine
The Supreme Court's rule-making power on plea bargaining in drug cases, as embodied in the Court-issued Plea Bargaining Framework in Drugs Cases, prevails over conflicting internal rules or guidelines of the Department of Justice. Judges may overrule the prosecution's objection if it is solely based on such executive issuances, provided the plea bargain conforms to the Court's framework and the court exercises sound discretion in approving it after considering factors such as the strength of evidence and the accused's background.