Facts:
Salvador A. Estipona, Jr. was accused in Criminal Case No. 13586 for violation of Section 11, Article II of Republic Act (R.A.) No. 9165 (Possession of Dangerous Drugs) in Legazpi City, where he was found in possession of 0.084 gram of methamphetamine hydrochloride or shabu. Estipona pleaded not guilty.
On June 15, 2016, Estipona filed a Motion to Allow the Accused to Enter into a Plea Bargaining Agreement, proposing to withdraw his not guilty plea and, instead, to enter a plea of guilty for a lighter offense, with rehabilitation in mind given he was a first-time offender and due to the minimal quantity of drugs seized. He argued that Section 23 of R.A. No. 9165, which prohibits plea bargaining in drug cases, was unconstitutional.
The prosecution opposed this motion based on Section 23 of R.A. No. 9165 but expressed openness to plea bargaining if not for the said section. On July 12, 2016, the Regional Trial Court (RTC) presided by Judge Frank E. Lobrigo denied the motion, and upon Estipona’s motion for reconsideration, it was again denied on July 26, 2016. Consequently, Estipona escalated the matter to the Supreme Court.
Issues:
1. Whether Section 23 of R.A. No. 9165 violates the constitutional right to equal protection of the law.
2. Whether Section 23 of R.A. No. 9165 encroaches upon the Supreme Court’s power to promulgate rules of procedure.
3. Whether the RTC committed grave abuse of discretion in refusing to declare Section 23 of R.A. No. 9165 as unconstitutional.
Court’s Decision:
The Supreme Court granted the petition, declaring Section 23 of R.A. No. 9165 unconstitutional. The Court emphasized its exclusive authority to promulgate rules concerning pleading, practice, and procedure according to Section 5(5), Article VIII of the 1987 Constitution. It concluded that plea bargaining is correctly considered a rule of procedure, hence within the Court’s domain, and not subject to legislative encroachment.
Doctrine:
The Supreme Court has the sole power to promulgate rules concerning pleading, practice, and procedure in all courts, and such rules shall not diminish, increase, or modify substantive rights.
Class Notes:
– The legal principle of separation of powers among the co-equal branches of government maintains that the judiciary has exclusive control over the promulgation of rules of procedure in the courts.
– Plea bargaining is a procedural component that enables the disposition of charges by the agreement of the parties subject to court approval.
– A substantive law creates, defines, and regulates rights; a procedural law prescribes the method of enforcing rights.
– The Supreme Court’s rule-making power is exclusively for rules that govern court procedures, and such rules cannot diminish, increase, or modify substantive rights.
Historical Background:
The case reflects the tension between the legislative intent to combat the drug menace with stringent legal provisions and the judiciary’s mandate to uphold constitutional principles, such as the separation of powers and judicial independence. It also highlights the evolving jurisprudence surrounding plea bargaining in the context of drug-related offenses.
Leave a Reply