Case Digest (G.R. No. L-14306)
Facts:
On June 13, 1951, Patrolman Jesus Cordero of Caloocan, Rizal, filed a complaint in the justice of the peace court against Pablo Calion and four others, charging them with coercion. The complaint alleged that on June 12, 1951, the defendants had forced Josefa de Castro Evangelista to abandon her house against her will, taking her furniture and belongings in the process. Before the defendants could enter their plea, the fiscal submitted a motion to dismiss the coercion complaint and instead sought to admit a new information for the crime of qualified trespass to dwelling. This new information claimed that the defendants unlawfully and violently entered Evangelista's house by forcibly opening the door and pushing her aside. Despite the defendants' objections, the judge granted the fiscal's motion. Subsequently, the defendants filed a motion to dismiss the new information, arguing that the court lacked jurisdiction to entertain the amendment or substitution of the ori...
Case Digest (G.R. No. L-14306)
Facts:
Incident and Initial Complaint:
- On June 12, 1951, Pablo Calion and four others allegedly forced Josefa de Castro Evangelista to abandon her house and removed her belongings, subsequently occupying the house.
- On June 13, 1951, Patrolman Jesus Cordero filed a complaint in the justice of the peace court of Caloocan, Rizal, charging the defendants with the crime of coercion.
Fiscal's Motion and New Information:
- Before the defendants could plead to the coercion charge, the fiscal filed a motion to dismiss the complaint and submitted a new information for qualified trespass to dwelling.
- The new information alleged that the defendants unlawfully and violently entered Josefa's house by forcibly opening the door and pushing her to gain entrance.
Defendants' Objections:
- The defendants objected to the fiscal's motion, arguing that the new information was an amendment to the original complaint, which changed the nature of the offense.
- They filed a motion to dismiss the new information, claiming the court lacked jurisdiction to entertain the amendment or substitution.
Court Proceedings:
- The trial court granted the fiscal's motion, dismissed the coercion complaint, and admitted the new information for qualified trespass to dwelling.
- The defendants filed certiorari and prohibition proceedings in the Quezon City Court of First Instance, which denied their petition.
- The case was elevated to the Court of Appeals and eventually forwarded to the Supreme Court due to questions of law.
Issue:
- Whether the filing of the new information for qualified trespass to dwelling constituted an amendment to the original complaint for coercion.
- Whether the substitution of the information violated the defendants' rights or procedural rules.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)