5/3/24, 9:00 AM Case Summary: G.R. No. 226679 - Estipona, Jr. y Asuela vs.
Lobrigo
Title
Estipona, Jr. y Asuela vs. Lobrigo
Case Ponente Decision Date
G.R. No. 226679 PERALTA, J Aug 15, 2017
The Supreme Court declares the prohibition against plea bargaining in drug cases
as unconstitutional, emphasizing its exclusive power to promulgate rules
concerning pleading, practice, and procedure, and recognizing the importance of
plea bargaining in expediting case disposition and promoting rehabilitation.
Case Summary (G.R. No. 226679)
Jur.ph v0.1-beta
Case Background and Parties Involved
The case of Estipona, Jr. v. Lobrigo involves the constitutionality of Section 23 of
Republic Act No. 9165, also known as the Comprehensive Dangerous Drugs Act of
2002.
The petitioner is Salvador Estipona, Jr., who is the accused in a drug possession case.
Estipona filed a motion to enter into a plea bargaining agreement, seeking to
withdraw his not guilty plea and instead plead guilty to a lesser offense.
The prosecution opposed the motion, citing the prohibition against plea bargaining in
drug cases under Section 23 of RA 9165.
The trial court denied Estipona's motion, leading him to file a petition for certiorari
and prohibition before the Supreme Court.
Main Issue: Constitutionality of Section 23 of RA 9165
The main issue in this case is the constitutionality of Section 23 of RA 9165, which
prohibits plea bargaining in drug cases.
The petitioner argues that this provision violates the rule-making power of the
Supreme Court and the equal protection clause of the Constitution.
The Supreme Court agrees with the petitioner and declares the prohibition against
plea bargaining in drug cases as unconstitutional.
Importance of Protecting the Rights of the Accused
The Court emphasizes the importance of protecting the rights of the accused.
https://jur.ph/jurisprudence/summary/estipona-jr-y-asuela-v-lobrigo 1/3
5/3/24, 9:00 AM Case Summary: G.R. No. 226679 - Estipona, Jr. y Asuela vs. Lobrigo
It acknowledges the gravity of the drug problem in the Philippines but also
recognizes that plea bargaining is a common practice in criminal cases.
The Court highlights the benefits of plea bargaining, such as the speedy disposition of
cases, conservation of judicial resources, and the opportunity for rehabilitation for the
accused.
Power of the Supreme Court to Promulgate Rules
The Court asserts that the power to promulgate rules concerning pleading, practice,
and procedure in all courts is vested exclusively in the Supreme Court.
It explains that procedural rules should be viewed as tools designed to facilitate the
attainment of justice and should not diminish, increase, or modify substantive rights.
The Court clarifies that plea bargaining is a procedural matter that does not infringe
on the accused's substantive rights.
Unconstitutionality of Section 23 of RA 9165
The Court concludes that Section 23 of RA 9165, which prohibits plea bargaining in
drug cases, is unconstitutional.
It invalidates the provision until and unless it is made part of the Rules of Court
through the rule-making power of the Supreme Court.
The Court emphasizes that the decision does not automatically mean that the
accused will be sentenced t... continue reading
Case Story (G.R. No. 226679)
Jur.ph v0.1-beta
1. The Supreme Court declares the prohibition against plea bargaining in drug cases as
unconstitutional, emphasizing its exclusive power to promulgate rules concerning
pleading, practice, and procedure, and recognizing the importance of plea bargaining
in expediting case disposition and promoting rehabilitation.
2. The petitioner in the case is Salvador Estipona, Jr. y Asuela.
3. The respondents in the case are Hon. Frank E. Lobrigo, the Presiding Judge of the
Regional Trial Court, Branch 3, Legazpi City, Albay, and the People of the Philippines.
4. The petitioner challenges the constitutionality of Section 23 of a certain law, which
provides for a plea-bargaining provision.
5. The facts of the case are not in dispute.
https://jur.ph/jurisprudence/summary/estipona-jr-y-asuela-v-lobrigo 2/3
5/3/24, 9:00 AM Case Summary: G.R. No. 226679 - Estipona, Jr. y Asuela vs. Lobrigo
6. The petitioner, Salvador Estipona, Jr., is the accused in Criminal Case No. 13586 for
violation of Section 11, Article II of a certain law, which pertains to the possession of
dangerous drugs.
7. The Information filed against the petitioner alleges that he unlawfully po...
Unlock Summary and Story
Get comprehensive understanding of the case
https://jur.ph/jurisprudence/summary/estipona-jr-y-asuela-v-lobrigo 3/3
