MANIFESTATION/

PLEA-BARGAINING PROPOSAL

COMES NOW accused, thru the undersigned Counsel,

most respectfully avers:

1. Accused was charged in Criminal Case No. R-DVO-

20-00887-CR with Violation of Section 11, in relation to
Section 25 of Republic Act No. 9165. The information therein
alleged that the plastic sachets recovered from the accused
contained traces of white crystalline substance or “shabu”.
The said quantity is within the plea-bargaining framework
provided by the Supreme Court;

2. Pursuant to Estipona v. Judge Lobrigo, G.R. No.

226679, August 15, 2017, the Supreme Court declared Section
23 (prohibition to plea-bargaining) of Republic Act No. 9165
unconstitutional. In relation thereto, OCA Circular No. 09-2018
was issued last January 17, 2018, informing all judges of the
Regional Trial Courts that the decision in the above-mentioned
case has become final and executory on November 7, 2017. On
April 10, 2018, the Supreme Court en banc issued a Resolution
in Administrative Matter No. 18-03-16-SC adopting the Plea
Bargaining Framework in Drugs Cases;

3. In view thereof, the accused would like to plead guilty

to the lower offense provided under Section 12 of the same law
where the imposable penalty is imprisonment from six (6)
months and one (1) day to four (4) years and a fine ranging from
Ten Thousand Pesos (P10,000.00) to Fifty Thousand Pesos
(P50,000.00);

4. In Criminal Case No. 32683, the accused was charged

with Violation of Section 28 (a) of Republic Act No. 10591. The
accused intends to plead guilty to the lesser provided under
Section 31 of the same law where the imposable penalty is
prision correccional and a fine of Ten Thousand Pesos
(P10,000.00)

5. The accused is a first time offender and her pure

intention in plea-bargaining is to expedite the proceedings and to
avail the benefits of Probation Law.

WHEREFORE, premises considered, it is most respectfully

manifested that the instant Manifestation/Proposal for Plea-
Bargaining be duly CONSIDERED, APPROVED and GIVEN
DUE COURSE by this Honorable Court by allowing accused to
plead guilty to proposed lesser offense under the same law.

Other reliefs, just and reasonable under the premises, are

likewise prayed for.

Davao City, Philippines, May 26, 2020.