G.R. No. 96161 - Philips Export B.V. vs. Court of Appeals

This case involves petitioner Honorata A. Labay and the People of the Philippines.
It is a Petition for Review on Certiorari under Rule 45, assailing previous decisions made by lower courts:

A Court of Appeals (CA) Decision dated October 24, 2017.
A CA Resolution dated September 6, 2018.
The decision of Branch 39 of the Regional Trial Court (RTC) of Calapan City, Oriental Mindoro, dated December 2, 2014, which found petitioner guilty of double registration.

Petitioner was charged with violating Section 10(j) in relation to Sections 45(j) and 46 of Republic Act (RA) No. 8189 (The Voter’s Registration Act of 1996).
The Information alleged that:

On or about December 26, 2001, during the continuing Registration of Voters, petitioner filed an application for registration at Precinct No. 109A in Barangay Maidlang 2, Calapan City, Oriental Mindoro.
In her application, she declared under oath that she was not a registered voter in any precinct of the city.
In reality, she was already a registered voter in Barangay Malitam, Batangas City, as evidenced by her Voter Registration Record (VRR) No. 22561463 dated June 22, 1997.

On June 22, 1997, petitioner filed an application for new voter registration with COMELEC-Batangas City.
She subsequently voted in the 1998 and 2001 elections in Batangas City.

Despite her earlier registration, petitioner filed another registration application with COMELEC-Calapan City on December 26, 2001.
When queried whether she was registered elsewhere, she denied it, leading COMELEC-Calapan to approve her application based solely on her sworn statement.

On July 2, 2002, petitioner sent a request to the City Election Officer of COMELEC-Batangas City for cancellation of her existing registration and the transfer of her records to Calapan City.
On July 18, 2002, COMELEC-Batangas City issued a certification confirming the cancellation of her VRR as of July 8, 2002.

Petitioner later filed a certificate of candidacy for a barangay chairman position in Calapan City during the July 15, 2002 barangay and Sangguniang Kabataan synchronized elections.
After her electoral victory, her opponent filed several cases against her, including the present case.

The RTC convicted petitioner beyond reasonable doubt of violating Section 10(j) in relation to Sections 45(j) and 46 of RA 8189.
The RTC imposed a penalty of imprisonment for one (1) year without the benefit of probation, along with accessory penalties such as disqualification from holding public office and deprivation of the right to vote.
The RTC underscored that double registration is treated as a malum prohibitum offense, making the intent of the petitioner immaterial.

On October 24, 2017, the CA affirmed the RTC’s conviction.
Petitioner filed a Motion for Reconsideration, which was denied in the CA Resolution dated September 6, 2018.

Petitioner elevated the case on certiorari claiming errors of law, including issues on the congruence between the charges and the conviction, and the constitutionality of Section 45(j) of RA 8189.

Whether petitioner was convicted of the same offense as that which was actually charged in the Information.

This issue examines the congruence between the contents of the Information and the conviction rendered by the RTC and affirmed by the CA.

Whether petitioner was duly informed of the cause of accusation of which she was convicted.

This issue addresses whether the Information provided sufficient and clear notice to the petitioner regarding the essential elements of the offense charged.

Petitioner argued that Section 45(j) violates constitutional guarantees, particularly the fair notice requirement under the 1987 Constitution, rendering it vague.