ANNEX “1”

Republic of the Philippines

REGIONAL TRIAL COURT
11th Judicial Region
Branch 9, Davao City

PEOPLE OF THE PHILIPPINES, Criminal Case No. 59,619-06

to59,621-06
-versus-

For: Violation of SEC. 11

MARK IAN SANTIAGO Y AQUINO,
and SEC. 12 of R.A. 9165
HELNO NAVARRO Y VILLEGAS &
MAZZIE LABADO Y LUMANTA,
Accused.
x- - - - - - - - - - - - - - - - - - - - - - - - - - - - x

PROPOSAL FOR PLEA BARGAINING

COMES NOW, the Accused, MARK IAN SANTIAGO Y AQUINO, through counsel, and
to this Honorable Court, respectfully states, that:

1. The accused is charged with the following offenses;

`
A. Violation of Section 11 of Article II of the Republic Act 9165 under Criminal
Case No. 59,619-06 for allegedly possessing 0.0522 grams of
Methamphetamine Hydrochloride; and

B. Violation of Section 12 of Article II of the Republic Act 9165 under Criminal

Case No. 59,620-06 for allegedly possessing a drug paraphernalia.

2. Accused respectfully invoke Supreme Court A.M. No. 18-03-16-SC (Adoption of

the Plea Bargaining Framework in Drugs Cases) dated April 10, 2018 which gives the
Honorable Court discretion to impose a minimum and a maximum period to be taken from the
range of the penalty provided by law. Upon approval of this proposal, he will plead guilty to the
lesser offense of Violation of Section 12 of Republic Act 9165 which is punishable by
imprisonment of six (6) months and one (1) day to four (4) years and a fine ranging from
Php10,000.00 to Php50,000.00 for all the foregoing cases.

PRAYER

WHEREFORE, PREMISES CONSIDERED, it is respectfully prayed that the Accused be

allowed to plead guilty to the lesser offense of Violation of Section 12 of Republic Act 9165 with
a straight penalty of six (6) months and one (1) day to one (1) year in accordance with Supreme
Court A.M. No. 18-03-16-SC (Adoption of the Plea Bargaining Framework in Drugs Cases)
dated April 10, 2018.

The accused is willing to undergo drug dependency test and if found negative for drug,
he respectfully prays that he be released on time served.
September 18, 2018 at Davao City, Philippines.
 MARK IAN A. SANTIAGO
Accused

PROS. SAMUEL ATENCIA ATTY. OSWALDO A. MACADANGDANG

Public Prosecutor Counsel for the Accused

Approved by:

PROS. NESTOR M. LEDESMA

City Prosecutor