Republic of the Philippines

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
Branch 282, Valenzuela City

PEOPLE OF THE PHILIPPINES

-versus- Criminal Case Nos. 921-V-18 to

922-V-18
ADRIAN GO y BARTOLEME, For: Violation of Sec. 5 and 11, Art.
Accused. II of R.A. 9165
x----------------------x

MOTION TO ALLOW THE ACCUSED TO ENTER INTO

PLEA BARGAINING AGREEMENT
(With Request for Drug Dependency Test)

COMES NOW, accused ADRIAN GO y BARTOLEME, 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 withdraw his not

guilty plea for violation of Sections 5 and 11, Article II of R.A. 9165
and enter instead a plea of guilty for violation of two counts of
Section 12, Article II of R.A. 9165; and

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

dependency test in order for this 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 this instant motion.

Other relief and remedies, just and equitable, are likewise prayed
for.

Valenzuela City, Metro Manila, 14 November 2018.

ADRIAN GO y BARTOLEME
Accused

With the assistance of:

PUBLIC ATTORNEY’S OFFICE

VALENZUELA DISTRICT OFFICE
3RD Floor, Comelec Bldg.
Justice Hall Compound, C.J. Santos St., Poblacion II
Malinta, Valenzuela City

Through:

ATTY. RAFAEL D. PANGILINAN

Public Attorney II
Roll No. 64684
IBP No. AR001704 dated 1/16/18 / CALMANA
MCLE Compliance No. VI - 0006876 dated 3/20/18

Notice of hearing:
Atty. Aireen M. Cacho-Jayme
Branch Clerk of Court
Regional Trial Court of Valenzuela City, Branch 282

Greetings! Please submit the foregoing motion for the

consideration and approval of the Honorable Court on 16 November
2018 at 8:30 in the morning.

ATTY. RAFAEL D. PANGILINAN

Copy furnished:
ACP Mary Jenneane Yambot
Office of the City Prosecutor of Valenzuela City
PSSupt. David Nicolas Poklay
Acting Chief of Police
PNP Valenzuela City Police Station