Republic of the Philippines

REGIONAL TRIAL COURT

Fifth Judicial Region
Branch 52
Sorsogon City

PEOPLE OF THE PHILIPPINES, CRIM. CASE NO. 16-9636

Plaintiff, FOR: VIOLATION OF SEC. 11
` ART. II, R.A. 9165 AS
-vs.- AMENDED BY R.A. 10640

SANDY MACANDOG y
SEMINIANO.
Accused.
X----------------------X

MOTION
[To Enter Into Plea Bargaining Agreement]

ACCUSED, by counsel, unto this Honorable Court, respectfully states,

THAT:

1. On January 2, 2016, accused was allegedly found to

have in his possession three (3) heat sealed transparent plastic
sachets allegedly containing 0.045 gram, 0.046 gram and 0.078 gram
or with an aggregate weight of 0.169 gram of methamphetamine
hydrochloride (shabu);

2. Thereafter Information for violation of Section 11,

Article II of R.A. 9165 was filed against the accused before this
Honorable Court under Criminal Case No. 16-9636;

3. On 10 April 2018, the Supreme Court En Banc issued

a Resolution which orders the adoption of a Plea Bargaining
Framework in Drug Cases (A.M. No. 18-03-16-SC). By virtue of said
A.M. No. 18-03-16-SC, those charged with violation of Section 11
(Possession of Dangerous Drugs) of methamphetamine
hydrochloride or “shabu” in quantities less than 0.99 grams are
now allowed to enter into a plea bargaining agreement;

4. Considering that the weight of the substances found

in the possession of the accused for alleged violation of Section 11
of R.A. 9165 is 0.169 gram, the accused humbly begs to avail the
benefits of plea bargaining agreement and fervently pray that he be
allowed to enter a plea to a lesser offense of Section 12 of R.A. 9165,
or Possession of Equipment, Instrument, Apparatus or other
Paraphernalia for Dangerous Drugs.
 PRAYER

WHEREFORE, premises considered, it is respectfully prayed of the

Honorable Court that this Motion to allow accused to enter into plea
bargaining agreement be duly granted.

Respectfully submitted, September 18, 2019, Sorsogon City,

Philippines.

CYRIL C. OROPESA
Counsel for the Accused
Rollo No. 54962
IBP No. 847640/January 2, 2014
PTR No. 147967/January 15, 2015
MCLE Compliance No. IV-0023763 UP Law Center
University of the Philippines, Diliman, Quezon City
#435 Market Site Sirangan, Sorsogon City
CP No. 09177672368/cyril_621975@yahoo.com

NOTICE

THE BRANCH CLERK OF COURT

Regional Trial Court, RTC-Branch 52
Hall of Justice, Sorsogon City

GREETINGS! Kindly submit the foregoing MOTION TO ENTER

INTO PLEA BARGAINING AGREEMENT on September 18, 2019, for
consideration and approval of the Honorable Court immediately upon
receipt hereof.

CYRIL C. OROPESA
Counsel for the Accused
Rollo No. 54962
IBP No. 847640/January 2, 2014
PTR No. 147967/January 15, 2015
MCLE Compliance No. IV-0023763 UP Law Center
University of the Philippines, Diliman, Quezon City
#435 Market Site Sirangan, Sorsogon City
CP No. 09177672368/cyril_621975@yahoo.com

NOTICE

THE BRANCH CLERK OF COURT

Regional Trial Court, RTC-Branch 52
Hall of Justice, Sorsogon City

THE HON. PROVINCIAL PROSECUTOR

Provincial Prosecution Office
Hall of Justice, Sorsogon City
 PLEASE be informed that the foregoing MOTION TO ENTER
INTO PLEA BARGAINING AGREEMENT will be submitted upon
receipt hereof without further arguments on September 18, 2019, at 8:30
o’clock in the morning at the Session Hall of the Regional Trial Court,
Branch 52- Sorsogon.

CYRIL C. OROPESA
Counsel for the Accused
Rollo No. 54962
IBP No. 847640/January 2, 2014
PTR No. 147967/January 15, 2015
MCLE Compliance No. IV-0023763 UP Law Center
University of the Philippines, Diliman, Quezon City
#435 Market Site Sirangan, Sorsogon City
CP No. 09177672368/cyril_621975@yahoo.com

Copy Furnished:

THE HON. PROVINCIAL PROSECUTOR

Provincial Prosecution Office
Hall of Justice, Sorsogon City