G.R. No. 249121 - Manalo II vs. People

On March 2, 2017, police conducted a search of petitioner Felix Nathaniel "Angel" Villanueva Manalo II's residence within the Iglesia Ni Cristo Compound in Quezon City pursuant to a search warrant.
Several unlicensed firearms and ammunition were seized during the search.
The Office of the City Prosecutor (OCP) of Quezon City investigated and, on March 3, 2017, found probable cause to charge petitioner and his companions with violations of Republic Act No. 10591 (Comprehensive Firearms and Ammunition Law).
The OCP Resolution ordered their release subject to the Inquest Chief’s approval.

Based on the OCP Resolution, petitioner was charged before the RTC under Sec. 28(b) of R.A. 10591 for illegal possession of three or more small arms or Class A light weapons without the required license or permit.
The OCP recommended "no bail" for petitioner.
Petitioner filed a Motion for Reinvestigation and a Motion to Fix Bail to counter the no-bail recommendation.
The OCP issued a Resolution dated September 14, 2017, affirming its previous finding of probable cause.

An OCP witness sought reconsideration to include charges involving conspiracy, violation of Sec. 28(e) of R.A. 10591 (which raised the penalty one degree higher), and complex crime of Direct Assault with Frustrated Murder.
Consequently, on October 9, 2017, the prosecution filed a Motion to Admit Attached Amended Information adding the violation under Sec. 28(e) and specifying that one shotgun was loaded with live ammunition.
The amended Information initially lacked signature approval by the City Prosecutor but later a version bearing City Prosecutor Donald T. Lee’s signature was submitted.

On November 20, 2017, RTC Branch 84 issued a Joint Resolution granting the motion to admit the amended Information and denying petitioner’s motion to fix bail, reasoning that petitioner was charged with a capital offense and the amendment was allowed before plea.
Petitioner filed a Manifestation pointing out tampering of the amended Information regarding the City Prosecutor’s signature.
He also filed motions for reconsideration and for inhibition against the judge handling the case, citing alleged partiality.

The case was raffled to a new RTC branch after the inhibition motions were granted.
On October 30, 2018, the new RTC Branch 216 denied petitioner’s motion for reconsideration, upheld the validity of the Amended Information, denied his bail motion, and disqualified the prosecution’s private counsel.

Petitioner filed a petition for certiorari before the CA contesting the RTC Joint Resolution and Omnibus Order’s rulings.
On August 30, 2019, the CA dismissed the petition and affirmed the RTC’s disposition, ruling that the amended Information was validly filed with the City Prosecutor’s eventual signature and petitioner was not entitled to bail as a matter of right due to the severity of the charged offense.

Bail is a matter of right because the original Information charged a divisible penalty below capital offenses.
The amendment was defective and invalid for lack of the City Prosecutor’s prior written approval and alleged tampering.
The amended Information cannot be cured by belated signing as this is jurisdictional.

Amendments before plea are allowed without court leave pursuant to Rule 110, Sec. 14 of the Rules of Court.
The deputy prosecutor’s signature was valid under a valid delegation of authority.
City Prosecutor Lee’s later approval cured any formal defect.
Bail was properly denied as petitioner was charged with a non-bailable capital offense (violation of Sec. 28(e) of R.A. 10591 with penalty reclusion perpetua to death).
Modifying or qualifying circumstances validly increase penalty classification under R.A. 10591 notwithstanding R.A. 9346 prohibiting death penalty.

Whether the Court of Appeals erred in finding no grave abuse of discretion by the RTC in upholding the validity of the Amended Information that charged the petitioner with a capital offense despite the initial lack of City Prosecutor’s approval.

Whether the Court of Appeals erred in ruling that the petitioner was not entitled to bail as a matter of right given the nature of the charge and the amended Information.