REPUBLIC OF THE PHILIPPINES

FOURTH JUDICIAL REGION

REGIONAL TRAIL COURT
BRANCH 83,
TANAUAN CITY, BATANGAS

THE PEOPLE
OF THE PHILIPPINES,
Plaintiff, CRIM. CASE NO.
22-09-1021, 22-09-1022
___________________________
- versus – viol. sec. 5 , & 11 Art. II
For: _______________________
R.A. No. 9165
___________________________
__________________________________,
VLADIMER RICALDE y OBERO

Accused.
x--------------------------------------------------------------------------------------------------x
MOTION TO PLEA BARGAIN

NOW accused _____________________________________,

VLADIMER RICALDE y OBERO through
the undersigned counsel and unto this Honorable Court most respectfully
submits the following Plea-Bargaining Proposal for the Honorable Court’s
consideration and approval, and states, THAT:

1. The accused has been charged for violation of

__________________,
SECTION 5, AND SECTION 11 Article II of the Republic Act No. 9165 otherwise
known as the Dangerous Drugs Act of 2002 (“R.A. No. 9165”);

2. The accused comes before the Honorable Court and proposes to

enter into a Plea Bargaining Agreement pursuant to Department Circular No.
018 dated 10 May 2022 issued by the Department of Justice, in accordance
with Administrative Matter No. 18-03-16-SC issued by the Supreme Court;
and taking into account the precedent brought about by the case of Salvador
Estipona, Jr. vs. Hon. Frank E. Lobrigo1 and in the case of Daan vs. Sandiganbayan
(G.R. Nos. 163972-77, March 28, 2008),2 allowing plea-bargaining even after
Pre-trial and giving the discretion to the Honorable Court to grant the same
during trial and even after the Prosecution has finished presenting its
evidence and rested its case.

3. As condition sine qua non for the Public Prosecutor to interpose

her consent, attached hereof a copy of the result of the accused’ Drug
Dependency Examination Report, for reference;

3. By reason of the foregoing matter, the accused hereby withdraws

his/her plea of not guilty and offers to enter a plea of guilty to the lesser
offense of violation of Section 12 under R. A. No. 9165 subject to the
conditions as may be imposed by the Court in accordance with the above-
referenced rules.
1 G.R.No. 226679, August 15, 2017.
2 People vs. Villarama (G.R. No. 99287, June 23, 210 SCRA 246.

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 WHEREFORE, premises considered, it is most respectfully prayed
upon this Honorable Court that this motion be considered and granted.

Other reliefs just and equitable are likewise prayed for.

RESPECTFULLY SUBMITTED.
____________________,
19 OCTOBER 2022 Tanauan City, Batangas.

Counsel for the Accused

DEPARTMENT OF JUSTICE
PUBLIC ATTORNEY’S OFFICE
2/F Dr. Salvador H. Laurel Memorial Building
(Legislative Bldg.)
Lauan St., Brgy. Pob. 3, Tanauan City, Batangas

By:

HEART C. LERO
Public Attorney II
Roll No. 61581
Lifetime IBP No. 015726
MCLE Compliance No. VI-0006454; 02.15.2018

NOTICE
Branch Clerk of Court
RTC Br. 83
Tanauan City, Batangas

Greetings.

Please submit the foregoing Motion for the utmost consideration of the Honorable
Court on _______________ or any date available on the Honorable Court’s
calendar.

HEART C. LERO
Public Attorney II
Copy furnished:

Pros. Maria Kristina Rivera-Torrecampo

______________________________
Provincial Prosecutor's Office,
______________________________
Tanauan City, Batangas
______________________________

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