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Vicente Suarez Jr. y Banua v. People of The Philippines

The Supreme Court reversed the Court of Appeals' decision, affirming Vicente Suarez Jr. y Banua's conviction for possession of drug paraphernalia after a plea bargain was initially granted by the trial court. The SC ruled that the prosecution waived its objection to the plea bargain by not raising the issue of drug quantity during proceedings, and remanding the case would violate Suarez's right against double jeopardy. The case highlights the importance of the Plea Bargaining Framework in drug cases and the implications of procedural waivers.

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220 views2 pages

Vicente Suarez Jr. y Banua v. People of The Philippines

The Supreme Court reversed the Court of Appeals' decision, affirming Vicente Suarez Jr. y Banua's conviction for possession of drug paraphernalia after a plea bargain was initially granted by the trial court. The SC ruled that the prosecution waived its objection to the plea bargain by not raising the issue of drug quantity during proceedings, and remanding the case would violate Suarez's right against double jeopardy. The case highlights the importance of the Plea Bargaining Framework in drug cases and the implications of procedural waivers.

Uploaded by

Grasya Pasquin
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Vicente Suarez Jr. y Banua v. People of the Philippines (G.R. No.

268672, December 4, 2023)

Facts:

Vicente Suarez Jr. y Banua (Suarez) was charged with violating Section 5, Article II of Republic
Act No. 9165 (selling 2.1585 grams of methamphetamine hydrochloride). He initially pleaded
not guilty but later moved to plead guilty to the lesser offense under Section 12 (possession of
drug paraphernalia). The trial court granted his motion despite the prosecution's objection,
convicting him under Section 12. The Court of Appeals (CA) reversed the trial court's decision,
nullifying the plea bargain and remanding the case for trial on the original charge. Suarez
appealed to the Supreme Court (SC).

Issues:

1. Did the trial court err in granting Suarez's plea bargain despite the prosecution's
objection and the quantity of drugs involved?

2. Does remanding the case violate Suarez's right against double jeopardy?

Ruling:

The SC reversed the CA's decision. The SC acknowledged that the trial court erred in granting
the plea bargain because the amount of shabu involved (2.1585 grams) precluded plea
bargaining under the Plea Bargaining Framework in Drugs Cases (A.M. No. 18-03-16-SC).
However, the SC found that the prosecution waived its objection by failing to raise the issue of
the quantity of drugs at any stage of the proceedings. The prosecution's objection was solely
based on the lack of its consent, not the inapplicability of plea bargaining due to the amount of
drugs.

The SC held that because Suarez had already been arraigned, pleaded guilty, and convicted
under the lesser offense, remanding the case to proceed with the original charge would violate
his right against double jeopardy. Therefore, the SC affirmed Suarez's conviction under Section
12, closing and terminating the case.

Doctrines Discussed:

 Plea Bargaining Framework in Drugs Cases (A.M. No. 18-03-16-SC): This framework sets
guidelines for plea bargaining in drug cases, including limitations based on the quantity
of drugs involved. For amounts exceeding certain thresholds, plea bargaining is not
allowed.

 Prosecutor's Consent in Plea Bargaining: While generally required, the prosecutor's


consent is not always indispensable. The trial court retains discretion, and objections
must be based on valid grounds, not merely procedural inconsistencies. The
prosecution's failure to raise a valid objection can be considered a waiver.

 Double Jeopardy: The constitutional right against double jeopardy protects an accused
from being prosecuted twice for the same offense after a valid conviction. The SC found
all the requisites of double jeopardy present in this case.

 Waiver: Procedural lapses, including the failure to raise a valid objection to a plea
bargain, can be waived if not timely raised.

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