Case Digest (G.R. No. 265585)
Facts:
Felix Nathaniel "Angel" Villanueva Manalo II v. People of the Philippines, G.R. No. 265585, April 15, 2024, Supreme Court Second Division, Lopez, J., writing for the Court.On March 2, 2017, police executed Search Warrant No. 5326(7) at petitioner Manalo's residence inside an Iglesia ni Cristo compound in Quezon City and allegedly recovered several unlicensed firearms and ammunition. The Office of the City Prosecutor of Quezon City filed Informations, including Criminal Case No. R‑QZN‑17‑03231‑CR charging Manalo under Section 28(b) of Republic Act No. 10591 for unlawful possession of firearms; the original Information listed three firearms but did not allege that any were loaded.
Manalo sought reinvestigation, which the Regional Trial Court (RTC), Branch 84, ordered; the city prosecutor affirmed probable cause. During pretrial proceedings the prosecution moved to amend the Information to allege that the 12‑gauge shotgun was “Loaded with seven (7) live ammunitions,” thereby invoking the qualified offense under Section 28(e) of RA 10591. RTC Branch 84 issued a Joint Resolution granting the prosecution’s motion to admit the Amended Information, denied Manalo’s motion to fix bail, and set arraignment and pretrial.
Manalo filed motions for reconsideration and to inhibit the presiding judge; the case was re‑raffled several times and eventually assigned to RTC Branch 216. On January 18, 2019, the trial court mistakenly read the original Information at arraignment; with counsel Manalo pleaded not guilty to the original Information. Upon discovery of the mistake, the prosecution moved for the Amended Information to be re‑read; when it was, Manalo refused to enter a plea and the trial court entered a plea of “not guilty” on his behalf.
Manalo moved to quash the Amended Information on the ground of double jeopardy (Rule 117, Sec. 3(i), Rules of Court). RTC Branch 216 denied the Motion to Quash and denied reconsideration, holding the Amended Information was the correct and only valid Information and that the court’s entry of a not guilty plea on Manalo’s behalf to the Amended Information was the valid plea. The Court of Appeals in CA‑G.R. SP No. 166960 affirmed the RTC, finding that the elements for the first jeopardy to attach were not established. Manalo filed a Petition for Review on Certiorari to this Court (Rule 45), contesting that the prosecu...(Subscriber-Only)
Issues:
- Should the Amended Information in Criminal Case No. R‑QZN‑17‑03231‑CR be quashed on the ground of double jeopardy...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)