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    Motion For Plea Bargain Black

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    Raffy Pangilinan
    The accused filed a motion to enter into a plea bargaining agreement with the prosecution for the crime of violation of Section 11, Article II of RA 9165. Specifically, the accused wishes to plead guilty to the lower offense of violation of Section 12, Article II of the same law. Additionally, the accused requested to immediately undergo a drug dependency test for the court to determine the proper penalty. The accused cited recent Supreme Court rulings and DOJ issuances allowing plea bargaining in drug cases.

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    Motion For Plea Bargain Black

    Uploaded by

    Raffy Pangilinan
    59 views2 pages
    The accused filed a motion to enter into a plea bargaining agreement with the prosecution for the crime of violation of Section 11, Article II of RA 9165. Specifically, the accused wishes to plead guilty to the lower offense of violation of Section 12, Article II of the same law. Additionally, the accused requested to immediately undergo a drug dependency test for the court to determine the proper penalty. The accused cited recent Supreme Court rulings and DOJ issuances allowing plea bargaining in drug cases.

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    The accused filed a motion to enter into a plea bargaining agreement with the prosecution for the crime of violation of Section 11, Article II of RA 9165. Specifically, the accused wishes to plead guilty to the lower offense of violation of Section 12, Article II of the same law. Additionally, the accused requested to immediately undergo a drug dependency test for the court to determine the proper penalty. The accused cited recent Supreme Court rulings and DOJ issuances allowing plea bargaining in drug cases.

    Copyright:

    © All Rights Reserved
    Download as DOC, PDF, TXT or read online from Scribd
    Download as doc, pdf, or txt
    59 views2 pages

    Motion For Plea Bargain Black

    Uploaded by

    Raffy Pangilinan
    The accused filed a motion to enter into a plea bargaining agreement with the prosecution for the crime of violation of Section 11, Article II of RA 9165. Specifically, the accused wishes to plead guilty to the lower offense of violation of Section 12, Article II of the same law. Additionally, the accused requested to immediately undergo a drug dependency test for the court to determine the proper penalty. The accused cited recent Supreme Court rulings and DOJ issuances allowing plea bargaining in drug cases.

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    © All Rights Reserved
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    of 2

    Republic of the Philippines

    NATIONAL CAPITAL JUDICIAL REGION


    REGIONAL TRIAL COURT
    Branch 282, Valenzuela City

    PEOPLE OF THE PHILIPPINES

    -versus- Criminal Case No. 1708-V-23


    For: Violation of Sec. 11, Art. II,
    ROLANDO BLACK, JR. y PADILLA, RA 9165
    Accused.
    x------------------------x

    MOTION TO ALLOW ACCUSED TO ENTER INTO


    PLEA BARGAINING AGREEMENT
    (With Request for Drug Dependency Test)

    Accused, assisted by the Public Attorney’s Office, unto this


    Honorable Court, most respectfully files this motion and avers that:

    1. In the landmark case of Estipona vs. Lobrigo, (G.R. 226679, 15


    August 2017) the Supreme Court has allowed plea bargaining in
    drug cases. Subsequently, the Supreme Court issued A.M. No. 18-
    03-16-SC or the “Adoption of the Plea Bargaining Framework in
    Drugs Cases.” Furthermore, the Office of the Solicitor General
    wrote a letter to the Acting Prosecutor General of the DOJ National
    Prosecution Service, Pros. Richard Anthony D. Fadullon, to the effect
    that it shall not file a petition for certiorari on criminal cases
    involving violation of R.A. 9165, which were mentioned in the said
    letter, as the motion for plea bargaining in those cases were in
    accordance with existing jurisprudence and the guidelines of the
    Supreme Court and the DOJ.

    2. Pursuant to the foregoing, accused would like to enter into a plea


    bargaining agreement with the prosecution and plead guilty to the
    lower offense of violation of Section 12, Article II of R.A. 9165.

    3. In addition, accused would like to immediately undergo a drug


    dependency test for the Honorable Court to determine the
    necessary penalty to be imposed in granting this motion.

    PRAYER

    WHEREFORE, premises considered, it is most respectfully prayed


    before this Honorable Court to grant the instant motion.

    Other relief and remedies, just and equitable, are likewise prayed
    for.
    Valenzuela City, Metro Manila, 01 December 2023.

    Assisted by:

    PUBLIC ATTORNEY’S OFFICE


    VALENZUELA DISTRICT OFFICE
    1 Floor, Metropolitan Trial Court Bldg.
    st

    Justice Hall Compound, C.J. Santos St., Poblacion II,


    Malinta, Valenzuela City

    Through:

    ATTY. RAFAEL D. PANGILINAN


    Public Attorney II
    Roll No. 64684
    IBP OR No. 257836 dated 1/2/2023 / CALMANA Chapter
    MCLE Compliance No. VII - 0024379 valid until 4/14/2025

    Copy furnished:
    SACP Ana Liza C. Dogma
    Office of the City Prosecutor of Valenzuela City
    [email protected] / [email protected]

    Explanation on the mode of service:


    Service of the foregoing motion was made to Office of the City Prosecutor
    of Valenzuela City, as well as the Honorable Court through electronic
    means in accordance with Section 3 (d), Rule 13 of the 2019 Amendments
    to the 1997 Rules of Civil Procedure.

    ATTY. RAFAEL D. PANGILINAN

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