The Supreme Court’s decision in Fernandez v. People clarifies that simply requesting a reduced penalty under a plea bargaining framework is insufficient. The accused must actively plead guilty to a lesser offense to benefit from reduced sentencing. This ruling underscores the importance of adhering to established legal procedures in criminal cases, particularly concerning drug offenses.

No Shortcut: Why Sentence Reduction Requires a Guilty Plea

Noel Fernandez and Andrew Plata sought to reduce their sentences for illegal possession of dangerous drugs without formally pleading guilty to a lesser offense. Their request was based on the subsequent adoption of a plea bargaining framework that offered more lenient penalties. However, the Supreme Court denied their plea, emphasizing that a plea of guilty to a lesser offense is a prerequisite for availing the benefits of plea bargaining. This case highlights the essential elements of plea bargaining and the necessity of adhering to procedural requirements.

The case originated from a joint judgment by the Regional Trial Court (RTC) finding Fernandez and Plata guilty of illegal possession of dangerous drugs under Section 11, Article II of Republic Act (R.A.) No. 9165, also known as the Comprehensive Dangerous Drugs Act of 2002. Both were sentenced to an indeterminate penalty of twelve (12) years and one (1) day as minimum term to fourteen (14) years as maximum term, and a fine of Four Hundred Thousand Pesos (P400,000.00). The Court of Appeals-Cebu City (CA-Cebu) affirmed the RTC’s decision. The petitioners then sought recourse from the Supreme Court, initially through a Petition for Review on Certiorari, which was denied due to procedural lapses. The denial was made final when their Motion for Reconsideration was also rejected.

Subsequently, Fernandez and Plata filed a Manifestation seeking leniency and the application of the plea bargaining framework outlined in A.M. No. 18-03-16-SC, arguing that plea bargaining was prohibited during their trial. The Supreme Court, however, denied this request, reiterating that a guilty plea to a lesser offense is indispensable for sentence reduction under the plea bargaining framework. This framework emerged from the ruling in Estipona v. Lobrigo, which declared unconstitutional Section 23 of R.A. No. 9165, which previously barred plea bargain deals in drug cases.

The Court emphasized that plea bargaining is a mutually agreed disposition between the accused and the prosecution, subject to court approval. According to the Court, plea bargaining in criminal cases is:

a process whereby the accused and the prosecution work out a mutually satisfactory disposition of the case subject to court approval. It usually involves the defendant’s pleading guilty to a lesser offense or to only one or some of the counts of a multi-count indictment in return for a lighter sentence than that for the graver charge.

This definition underscores the consensual nature of plea bargaining, where both parties must agree to the terms, and the court must ultimately approve the arrangement.

Section 2, Rule 116 of the Rules of Court further elaborates on the process of pleading guilty to a lesser offense, stating:

SEC. 2. Plea of guilty to a lesser offense. — The accused, with the consent of the offended party and the fiscal, may be allowed by the trial court to plead guilty to a lesser offense, regardless of whether or not it is necessarily included in the crime charged, or is cognizable by a court of lesser jurisdiction than the trial court. No amendment of the complaint or information is necessary.

This provision sets the legal foundation for plea bargaining, outlining the conditions under which an accused may plead guilty to a lesser offense.

The Supreme Court identified four basic requisites for plea bargaining: (1) consent of the offended party; (2) consent of the prosecutor; (3) plea of guilty to a lesser offense necessarily included in the offense charged; and (4) approval of the court. Among these, the plea offer is the most critical. Without it, there is no plea bargain and no basis for reducing the sentence. The Court noted that Fernandez and Plata sought sentence reduction based solely on the issuance of the plea bargaining framework, without offering a plea of guilty to a lesser offense.

The Court referenced People v. Magat, stating that:

it is the essence of a plea of guilty that the accused admits absolutely and unconditionally his guilt and responsibility for the offense imputed to him.

Therefore, without a categorical admission of guilt for a lighter offense, the accused must face the penalty prescribed for the offense to which they actually pleaded. In this case, Fernandez and Plata were required to serve the original sentence of imprisonment for twelve (12) years and one (1) day to fourteen (14) years imposed by the RTC. The decision reiterates that new guidelines alone do not automatically warrant a sentence reduction; a formal plea and acceptance by the court are still mandatory.

FAQs

What was the key issue in this case?	The key issue was whether the petitioners could avail of a reduced sentence under a plea bargaining framework without actually pleading guilty to a lesser offense. The Supreme Court ruled that a guilty plea is a mandatory prerequisite for such reduction.
What is plea bargaining?	Plea bargaining is a process where the accused and the prosecution agree on a mutually satisfactory disposition of the case, typically involving pleading guilty to a lesser offense for a lighter sentence. This agreement is subject to court approval.
What was the ruling in Estipona v. Lobrigo?	In Estipona v. Lobrigo, the Supreme Court declared unconstitutional Section 23 of R.A. No. 9165, which barred plea bargaining in drug cases. This decision paved the way for the adoption of a plea bargaining framework in drug-related offenses.
What are the requisites for plea bargaining?	The four basic requisites for plea bargaining are: (1) consent of the offended party; (2) consent of the prosecutor; (3) plea of guilty to a lesser offense necessarily included in the offense charged; and (4) approval of the court.
Why was the petitioners’ request for sentence reduction denied?	The request was denied because the petitioners sought a reduction based solely on the existence of a plea bargaining framework, without actually pleading guilty to a lesser offense.
What happens if an accused does not admit guilt for a lighter offense?	If an accused does not categorically admit guilt for a lighter offense, they must face the penalty prescribed for the offense to which they actually pleaded, as determined by the court.
What is the significance of A.M. No. 18-03-16-SC?	A.M. No. 18-03-16-SC refers to the plea bargaining framework adopted by the Supreme Court in cases involving illegal drugs, following the ruling in Estipona v. Lobrigo. It provides guidelines for plea bargaining in drug-related offenses.
Does a new sentencing guideline automatically warrant a sentence reduction?	No, new sentencing guidelines do not automatically warrant a sentence reduction. A formal plea to a lesser offense and its acceptance by the court are still mandatory.

In conclusion, the Supreme Court’s resolution in Fernandez v. People serves as a clear reminder of the procedural requirements for plea bargaining. It emphasizes that a mere request for a reduced penalty is insufficient; a formal plea of guilty to a lesser offense is essential. This decision reinforces the integrity of the legal process and ensures that plea bargaining is conducted within established guidelines.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: Noel Fernandez y Villegas and Andrew Plata y Sumatra v. People of the Philippines, G.R. No. 224708, October 02, 2019