G.R. No. 53552 - Philippine Long Distance Telephone Co. vs. National Labor Relations Commission

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G.R. No. 53552: Philippine Long Distance Telephone Co. vs. National Labor Relations Commission

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Title Source: Supreme Court: Fronda-Baggao vs. People

Case: G.R. No. 151785

Decision Date: Dec 10, 2007

Petitioner evaded arrest for a decade; four illegal recruitment cases amended into one before arraignment, upheld by SC as permissible under procedural rules.

Case Digest (G.R. No. 53552)
Expanded Legal Reasoning Model

Facts:

Initial Filing and Arrest

In 1989, the Provincial Prosecutor of Abra filed four separate Informations for illegal recruitment against Susan Fronda-Baggao and Lawrence Lee (Criminal Cases Nos. 744, 745, 746, and 749).
Susan Fronda-Baggao, the petitioner, evaded arrest for over a decade, leading to the archival of the cases.
Petitioner was finally arrested on July 25, 1999.

Motion to Amend the Informations

On July 26, 1999, the prosecutor filed a motion with the Regional Trial Court, Branch 1, Bangued, requesting that the four separate Informations for illegal recruitment be consolidated into a single Information for illegal recruitment in large scale.
The trial court initially denied the motion for amendment due to lack of merit.

Reconsideration and Subsequent Order by the Trial Court

On August 6, 1999, following the denial, the prosecutor filed a motion for reconsideration.
The trial court, on January 26, 2000, granted the motion for reconsideration.

The Court set aside its earlier Order denying the motion to amend.
The four Informations were consolidated and substituted by one Information for illegal recruitment in large scale.
The case was forwarded to RTC, Branch 2, a Special Criminal Court, since illegal recruitment by a syndicate or in large scale qualifies as an offense involving economic sabotage.

Petitioner’s Subsequent Actions

Petitioner filed her own motion for reconsideration before the trial court, which was denied on March 21, 2000.
On April 11, 2000, petitioner elevated the matter by filing a petition for certiorari and prohibition with the Court of Appeals (docketed as CA-G.R. SP No. 58270), seeking:

The issuance of a preliminary injunction and/or a temporary restraining order.
A reversal of the trial court’s amendments.

The Court of Appeals rendered a decision on August 29, 2001, denying her petition.
A subsequent motion for reconsideration before the Court of Appeals was also denied in its Resolution dated January 15, 2002.

Escalation to the Supreme Court

Petitioner raised a Petition for Review on Certiorari under Rule 45 of the 1997 Rules of Civil Procedure.
The main contention centered on whether the amendment and consolidation of the four Informations into one was procedurally and substantively proper.

Issues:

Procedural Issue

Whether the four separate Informations for illegal recruitment could be amended and joined into a single Information for illegal recruitment in large scale, given that Section 14, Rule 110 of the Revised Rules on Criminal Procedure appears to refer to an amendment of a single Information.

Substantive Rights Issue

Whether such an amendment, which consolidates multiple charges into one involving a graver offense (illegal recruitment in large scale), violates the substantial rights of the petitioner.
Specifically, whether this consolidation impacts her right to bail, which she had previously availed of.

Ruling:

(Subscriber-Only)

Ratio:

(Subscriber-Only)

Doctrine:

(Subscriber-Only)

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END