G.R. No. 83551 - Albano vs. Reyes

On October 25, 2009, Gian Dale Galindez allegedly jumped from the 26th floor of a condominium, resulting in his death. He was in the company of petitioner Norman Alfred F. Lazaro and their friend Kevin Jacob Escalona at the time.
Galindez’s father filed a criminal complaint for Giving Assistance to Suicide (Art. 253, RPC) against Lazaro and Escalona. The Pasig City Prosecutor’s Office found probable cause and filed an Information, which was briefly set aside by the DOJ but later reinstated on motion for reconsideration.

May 17, 2010: Information filed before RTC Pasig, Branch 261; Lazaro arraigned February 9, 2011 and entered a plea of not guilty by court order.
August 13, 2013: Escalona moved to quash the Information for failure to state an offense.
October 23, 2013: RTC granted the Motion to Quash but, in the same dispositive paragraph, directed the prosecutor to file an amended Information within ten days—creating a clear conflict between dismissal and amendment.
December 6, 2013: Prosecutor filed the Amended Information 17 days after receipt of the RTC’s order (beyond the ten-day period). Lazaro moved to expunge. Prosecutor then filed a Motion for Clarification (March 28, 2014).
August 4, 2014 (First Assailed Order): RTC clarified its October 23, 2013 order, amending the dispositive portion to show its true intent—to allow amendment under Sec. 4, R.R.Crim.P.—and overruled Lazaro’s motions to expunge.
January 21, 2015 (Second Assailed Order): RTC denied Lazaro’s motion for reconsideration, holding that the original order never meant to dismiss the case.
Lazaro filed a Rule 65 petition for certiorari with the CA (CA-G.R. SP No. 139927).
June 16, 2016 (Assailed Decision) and February 15, 2017 (Assailed Resolution): CA denied Lazaro’s petition and his motion for reconsideration.

Whether the Court of Appeals committed serious reversible error in affirming the RTC’s modification and clarification of its October 23, 2013 order.