CASE DIGEST : EDWIN AGUILAR Y DURON v. PEOPLE GR No. 257410, Aug 09, 2023 GAERLAN

FACTS : The case arose from two criminal informations filed against Edwin Aguilar for illegal sale (Section 5) and illegal possession (Section 11) of shabu under Republic Act No. 9165 after he allegedly sold one sachet of shabu to a police poseur-buyer and was found in possession of seven more sachets. During pre-trial, Aguilar sought to avail of plea bargaining under A.M. No. 18-03-16-SC, offering to plead guilty instead to violations of Section 12 of the law. Although the prosecution opposed the proposal on the ground that it was inconsistent with the Department of Justice's plea bargaining guidelines, the Regional Trial Court granted Aguilar's proposal, ruling that the Supreme Court's Plea Bargaining Framework, as recognized in Estipona v. Lobrigo, prevails over DOJ guidelines. The RTC consequently convicted Aguilar of the lesser offense in both cases and imposed reduced penalties, further noting that a drug dependency evaluation found him not to be drug dependent.

The People, through the Office of the Solicitor General, challenged the RTC's ruling via a petition for certiorari, arguing that the trial court committed grave abuse of discretion by approving the plea bargain despite the prosecution's express objection. The prosecution maintained that its consent is an indispensable prerequisite to any valid plea bargaining agreement and that neither Estipona nor A.M. No. 18-03-16-SC authorized trial courts to disregard such objection. The Court of Appeals agreed, relying on Sayre v. Xenos, which held that plea bargaining requires the consent of the accused, the offended party, and the prosecutor, and that the proposed lesser offense must necessarily be included in the offense charged. Accordingly, the CA nullified the RTC's decision, ordered the continuation of the criminal proceedings, and later denied Aguilar's motion for reconsideration, citing People v. Reafor, which reiterated that absent a mutual plea bargaining agreement, trial must proceed. Aguilar then elevated the case to the Supreme Court, arguing that the CA erred in setting aside the RTC's approval of his plea bargain.

ISSUE : WON the CA erred in granting the petition

HELD: The Supreme Court held that plea bargaining in drug cases is governed by the Court's Plea Bargaining Framework, as harmonized with DOJ Circular No. 18, and remains subject to the sound discretion of the trial court. While plea bargaining generally requires the mutual agreement of the parties, the trial court may overrule the prosecution's objection when such objection is based solely on alleged inconsistency with DOJ guidelines, provided that the accused's proposal conforms to the Court-issued Plea Bargaining Framework. However, before approving a plea bargaining proposal, the trial court must determine whether the accused is disqualified, such as when the accused is a recidivist, habitual offender, known drug addict, has relapsed after rehabilitation, or has been charged multiple times, or when the evidence of guilt is strong. In the absence of such determination, the approval of the plea bargain is premature, and the case must be remanded to enable the trial court to evaluate the existence of these disqualifying circumstances before ruling on the accused's plea bargaining proposal.