Republic of the Philippines

Regional Trial Court

9th Judicial Region
Branch ----
CITY, PROVINCE

PEOPLE OF THE PHILIPPINES, Criminal Case No. K-XXXX

Plaintiff,

-versus- -for-

MR. ABCD ILLEGAL SALE OF

Accused. DANGEROUS DRUGS

PEOPLE OF THE PHILIPPINES, Criminal Case No. K-XXXX

Plaintiff,

-versus- -for-

MR. ABCD ILLEGAL POSSESSION OF

Accused. DANGEROUS DRUGS

MOTION TO ENTER
INTO PLEA BARGAINING AGREEMENT

Comes now, the accused MR. ABCD, through counsel, unto this Honorable

Court, most respectfully alleges:

1. That the accused is charged for the Violation of Section 5 and Section 11

of R.A. 9165, presently pending before the Regional Trial Court Branch

XX, CITY, PROVINCE, ;

2. That the accused is presently under the custody of Bureau of Jail

Management and Penology (BJMP), CITY, PROVINCE;

3. That the accused is offering to enter into a plea bargaining agreement to

plea bargain to a lesser offense of Violation of Section 12 of R.A. 9165

which carries with it the penalty of 6 months and 1 day to 4 years and a

fine ranging from P10,000.00 to P50,000.00 for each of the charge

against the accused;

1
 4. That the total weight of the Methamphetamine Hydrochloride involved in

the alleged Violation of Sec 5, RA 9165 is 0.011 grams;

5. That the total weight of the Methamphetamine Hydrochloride involved in

the alleged Violation of Sec 11, RA 9165 is 0.011 grams;

6. That this plea bargaining offer is allowed by law and is in accordance with

A.M. No. 18-03-16-SC wherein the Supreme Court orders the adoption of

the Plea Bargaining Framework in Drugs Cases.

WHEREFORE, it is respectfully prayed unto this Honorable Court that this

Plea Bargaining Offer be accepted and admitted, and find the said offer proper and

in place, and the same be allowed.

Other reliefs, which are just and equitable, are also prayed for.

CITY, PROVINCE. _____________, 2018.

XYZ LAW OFFICE

Counsel for the Accused
LAW OFFICE ADDRESS By:
ATTY. XYZ
Roll of Attorney No. 12345
IBP No. 6789 for 2018
MCLE Compliance No. VI – 0000XXX

COPY FURNISHED:

1. XXXXXXX
Office of the Provincial Prosecutor
CITY, PROVINCE

2. Philippine Drug Enforcement Agency

CITY, PROVINCE