Republic of the Philippines

REGIONAL TRIAL COURT

Fourth Judicial Region
Branch 80
Morong, Rizal

PEOPLE OF THE PHILIPPINES, Criminal Case No. 22-24972-M

-Plaintiff,

-versus- For:

NONITO LOCASIA y Cerocam Violation of Section 5 of R.A. No. 9165

alias “Balot”,
Accused.
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PEOPLE OF THE PHILIPPINES, Criminal Case No. 22-24973-M
-Plaintiff,

-versus- For:

NONITO LOCASIA y Cerocam Violation of Section 11 of R.A. No. 9165

alias “Balot”,
Accused.
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COMMENT/OBJECTION

THE PROSECUTION, through the undersigned public prosecutor, unto this

Honorable Court, most respectfully submits its comment/objection to the Motion to Plea
Bargain, and hereunder alleges THAT:

1. On April 14, 2023, the accused filed before this Honorable Court a Motion to
Plea Bargain;

2. In said motion, accused sought for the approval of the Honorable Court that
he be allowed to plea bargain from the original charges for Violation of
Sections 5 and 11 of R.A. 9165 to Violation of Section 12 of R.A. 9165;

3. Accused, in his motion, cited A.M. No. 18-03-16-SC issued by the Supreme
Court as his legal basis for his desire to enter into a plea bargaining
agreement with the prosecution;

4. On the basis of A.M. No.18-03-16-SC, prior consent of the prosecution is

required before the accused may be allowed to enter into a plea bargaining
agreement;

5. Considering the quantity of the drugs involved in Criminal Case No.

22-24972-M for Violation of Section 5 of R.A. 9165 and in Criminal Case No.
22-24973-M for Violation of Section 11 of R.A. 9165 is considered within the
framework provided for the DOJ Department Circular No. 018, dated May 10,
2022, the Prosecution offers NO OBJECTION thereto provided further, that
the imposable penalty for Section 12 (to plead guilty from Section 5 of RA
9165) and for Section 12 (to plead guilty for Section 11, Par. 3 of RA 9165)
should be within a period of six (6) months and one (1) day to four (4) years
and a fine raging from ₱10,000.00 to ₱50,000.00, whichever the Court may
find applicable’;
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WHEREFORE, premises considered, it is most respectfully prayed for that

foregoing Comment to the Motion for Plea Bargaining of the prosecution be taken into
consideration by the Honorable Court in the resolution of said motion.

Taytay, Rizal
April 17, 2023.

Department of Justice
National Prosecution Service
Rizal Provincial Prosecution Office
RPJ Compound, Brgy. Dolores
Taytay, Rizal

By:

BREND VIRGILIO S. VERGARA

Prosecutor I

Copy Furnished:

ATTY. JOHN VON LEE L. DE LUNA

Counsel for the Accused
Public Attorney’s Office
Morong, Rizal
(jld.pao@gmail.com)