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

AQUINO V. PEOPLE [ G.R. No. 259094, January 28, 2025 ]
Posted by:PJP
Interactive Case Summary: Aquino v. People

SUPREME COURT - EN BANC

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

RODULFO FERRAREN AQUINO A.K.A. "YOYON", PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

Case Summary: Plea Bargaining in Drug Cases

  • This landmark decision clarifies the power of trial courts in plea bargaining for drug cases. The Supreme Court, guided by its ruling in *People v. Montierro*, held that a trial court may overrule the prosecution's objection to a plea bargain if the objection is based *solely* on an internal Department of Justice (DOJ) circular that contradicts the Supreme Court's Plea Bargaining Framework. The Court also introduced supplementary guidelines, applying the Omnibus Motion Rule, which states that any ground for objection not raised by the prosecution is deemed waived, thereby streamlining the process and preventing unnecessary remands.
  • The Charges: Rodulfo Aquino was charged in two separate Informations for Illegal Sale of 0.18 gram of *shabu* (Section 5, R.A. 9165) and Illegal Possession of 1.84 grams of *shabu* (Section 11, R.A. 9165).
  • Plea Bargain Offer: Aquino offered to plead guilty to the lesser offense of Possession of Drug Paraphernalia (Section 12, R.A. 9165) for both charges, which is an acceptable plea under the Supreme Court's Plea Bargaining Framework (A.M. No. 18-03-16-SC).
  • Prosecution's Objection: The prosecutor consented to the plea bargain for the illegal possession charge but objected to the one for the illegal sale charge, arguing that it was prohibited under the then-effective DOJ Department Circular No. 027.
  • RTC Ruling: The RTC granted Aquino's motion for both charges, overruling the prosecution's objection by prioritizing the Supreme Court's framework over the DOJ's circular. Aquino was re-arraigned and convicted of the lesser offenses on the same day.
  • Court of Appeals (CA) Ruling: On a petition for *certiorari* by the OSG, the CA annulled the RTC's judgment, ruling that the consent of the prosecutor is a mandatory requirement for plea bargaining.
  • Can a trial court approve a plea bargain in a drug case over the prosecution's objection if the objection is based solely on a DOJ circular inconsistent with the Supreme Court's Plea Bargaining Framework?

The Supreme Court GRANTED the petition, REVERSED the CA, and REINSTATED the RTC's Joint Judgment.

  • Application of *Montierro* Doctrine: The Court applied the controlling doctrine from *People v. Montierro*, which held that courts may overrule the prosecution's objection to a plea bargain if it is based solely on an executive issuance (like a DOJ circular) that contradicts a Court-issued rule (like the Plea Bargaining Framework). This is a valid exercise of the Court's exclusive constitutional power to promulgate rules of procedure.
  • New Supplementary Guidelines: To avoid unnecessary remands and delays, the Court introduced new guidelines applying the Omnibus Motion Rule. If the prosecution objects to a plea bargain on one ground, it is deemed to have waived all other grounds (e.g., strength of evidence, character of the accused).
  • RTC Decision Reinstated: Since the prosecution's only objection was based on the DOJ circular—a ground the RTC correctly overruled under the *Montierro* doctrine—and no other grounds were raised, the RTC's decision to grant the plea bargain and convict Aquino of the lesser offenses was reinstated.
  • Judicial Discretion in Plea Bargaining: A court may overrule the prosecution's objection to a plea bargain in a drug case if the objection is based *only* on an internal DOJ guideline that contradicts the Supreme Court's established plea bargaining framework.
  • Supremacy of Judicial Rules: The Supreme Court's power to promulgate rules of procedure is exclusive and cannot be undermined by administrative issuances from the executive branch.
  • Omnibus Motion Rule in Plea Bargaining: The prosecution must raise all available objections (e.g., strength of evidence, character of the accused) when opposing a plea bargain. Any ground not raised is considered waived.