Republic of the Philippines

REGIONAL TRIAL COURT

BRANCH 23
Olangapo City

PEOPLE OF THE PHILIPPINES,

Complainant,
Criminal Case No. 22407-22508

For: “Viol. of RA 9165 (Sale and

-versus-
Possession)”
JUAN DELA CRUZ,
Accused.

MOTION FOR CONSOLIDATION AND TO ENTER INTO PLEA BARGAINING

AGREEMENT

ACCUSED, by undersigned counsel, unto the Honorable Court, most respectfully states
that:
1. Accused is charged under Section 5 and 11 of RA 9165 for allegedly selling and being
in possession of 4.8470 grams of dried marijuana leaves and 5.2974 grams of the same,
respectively.
2. Both offenses are a result of a single incident and hence involves the same witnesses
and set of evidence.
3. For purposes of judicial expedience, it is necessary that both cases be consolidated.
4. Furthermore, A.M. No. 18-03-16-SC (Adoption of the Plea Bargaining Framework in
Drugs Cases) dated April 10, 2018 allows the Plea Bargaining of both Section 5, Sale of
Dangerous Drugs and Section 11, Possession of Dangerous Drugs to Section 12, Possession of
Equipment, Instrument, Apparatus and Other Paraphernalia for Dangerous Drugs.
5. Accused desires to enter into a plea bargaining agreement with the State with the
approval of the Honorable Court, allowing him to enter a plea of guilty to the offense of violation
of Section 12 of RA 9165, as allowed under the Plea Bargaining Framework cited above.
WHEREFORE, premises considered, it is most respectfully prayed of the Honorable Court
to:
1) CONSOLIDATE the above-captioned cases, and
2) ALLOW and APPROVE accused’s Motion to Enter into a Plea Bargaining
Agreement.
Other relief just and equitable are likewise prayed for. Olongapo City. August 4, 2021.

PEDRO PENDUKO
Attorney

The BRANCH CLERK OF COURT, This Court

The HON. CITY PROSECUTOR
 GREETINGS: Please take notice that the foregoing Motion shall be submitted for the kind
consideration and approval of the Honorable Court after a Comment from the State or the
expiration of its period. Thank you.

PEDRO PENDUKO
Copy furnished by electronic mail due to lack of messengerial services to:
Hon. Prosie Prosecutor
Asst. City Prosecutor

The Chief of Police

PNP, Olongapo City