G.R. No. 161067 - Ferrer, Jr. vs. Sandiganbayan

On March 6, 1946, the petitioner, Jose Guinto, was charged in the People’s Court with the crime of treason.
The charge alleged that from November 1, 1944 to February 3, 1946, in Manila, Guinto, a Filipino citizen owing allegiance to the United States and the Commonwealth of the Philippines, intentionally and unlawfully gave aid and comfort to the enemy by serving as a spy and informer for the Japanese Military Police.
An overt act specifically charged was the arrest and subsequent killing of Ernesto Simpao, a guerrilla, on December 15, 1944.

On May 25, 1945, before the petitioner pleaded, the Office of the Official Prosecutors filed an amended information by way of bill of particulars.
The amendment specified additional overt acts committed by the petitioner, including:

Assisting Japanese spies in arresting Albino Rutao, a guerrilla, on October 29, 1944, who was never seen again.
Helping Filipino spies arrest Ariston Tamon and another guerrilla on January 24, 1945; both were punished and taken to unknown locations, never seen again.
Assisting Japanese spies in arresting Felix de Leon, a guerrilla, also on January 24, 1945, who was never seen again.

The petitioner’s counsel moved to quash the additional overt acts in the amended information, arguing that the amendment amounted to a new information filed after the six-month period prescribed by Commonwealth Act No. 682 had lapsed.
The People’s Court denied the motion to quash and the subsequent motion for reconsideration.
Petitioner filed a petition for certiorari to the Supreme Court, alleging that respondents acted in excess of jurisdiction by admitting the amended information.

Section 2 of Act No. 682 gave the People’s Court jurisdiction over crimes against national security committed between December 8, 1941 and September 2, 1945, only if cases were filed within six months from the passage of the Act.
If cases were filed after the six-month period, jurisdiction lies with the proper Court of First Instance.

Whether the People’s Court acted within its jurisdiction in admitting the amended information filed beyond the six-month period prescribed by Commonwealth Act No. 682, albeit the original information was filed within that period.

Whether an amended information specifying additional overt acts to support the original charge of treason constitutes a new case or a continuation of the original case.

Whether the amended information violates procedural rules or the period limit for filing cases under Act No. 682.