.png "CERTIFIED PARALEGALS & LEGAL RESEARCHERS"){kind=small}
AQUINO V. PEOPLE [ G.R. No. 259094, January 28, 2025 ]
RODULFO FERRAREN AQUINO
V.
PEOPLE OF THE PHILIPPINES
G.R. NO. 259094, JANUARY 28, 2025
Summary of Doctrines
- The power of the trial court to overrule the prosecution's objection to a plea bargaining proposal in drug cases is a recognition of the Supreme Court's exclusive rule-making power. A court may overrule an objection when it is based solely on the ground that the accused's proposal is inconsistent with an internal rule or guideline of the Department of Justice, even if it is in accordance with the plea bargaining framework issued by the Court.
- Plea bargaining is not a matter of right but is addressed entirely to the sound discretion of the court. However, this discretion is not unbridled and is circumscribed by the Court-issued framework on acceptable plea bargains, as well as by the evidence and circumstances of each case.
- A court may not allow plea bargaining if the prosecution's objection is valid and supported by evidence showing that the accused is a recidivist, habitual offender, or has a strong evidence of guilt. The trial court is mandated to hear and rule on the merits of such objections.
- In accordance with the principle behind the **Omnibus Motion Rule**, when the prosecution's objection to an accused's plea bargaining motion is based on only a few grounds, it is understood that it has waived any other possible grounds not raised.
- The practice of remanding a case to the trial court to determine the strength of the prosecution's evidence and the character of the accused—when the prosecution itself did not raise these objections—is anathema to the objectives of plea bargaining, which are to promote a speedy, inexpensive, and final disposition of every action and proceeding.
RODULFO FERRAREN AQUINO
V.
PEOPLE OF THE PHILIPPINES
G.R. NO. 259094, JANUARY 28, 2025
FACTS:
Petitioner Rodulfo Ferraren Aquino was charged with the illegal sale and possession of dangerous drugs. During his arraignment, he pleaded not guilty but later filed a motion for plea bargaining, seeking to plead guilty to the lesser offense of illegal possession of drug paraphernalia. The prosecution objected to this, citing a Department of Justice circular that did not allow such a plea bargain. The Regional Trial Court (RTC) overruled the objection, granted the motion, and convicted Aquino of the lesser offense. The Court of Appeals (CA) reversed this ruling, holding that the prosecution's consent was necessary. The case was then brought to the Supreme Court for resolution.
ISSUE:
The central issue was whether the trial court acted with grave abuse of discretion in allowing the accused to plead guilty to a lesser offense despite the prosecution’s objection, which was based solely on an internal Department of Justice circular.
RULING:
The Supreme Court ruled in favor of Aquino, reversing the Court of Appeals' decision and reinstating the RTC’s judgment. The Court, relying on its recent pronouncements in **People v. Montierro**, clarified its exclusive rule-making power. It held that trial courts may overrule a prosecution’s objection to a plea bargaining proposal if the objection is based only on an internal DOJ rule that is inconsistent with the Court's own plea bargaining framework. The Court further clarified that if the prosecution fails to raise all available objections, such as the strength of the evidence or the character of the accused, those objections are deemed waived, in accordance with the principle of the **Omnibus Motion Rule**. The Supreme Court noted that this approach promotes the objectives of plea bargaining, which are to secure a speedy, inexpensive, and final disposition of cases, rather than prolonging them through unnecessary remands.