G.R. No. 265585 - Manalo vs. People

On March 2, 2017, police officers conducted a search and seizure operation at Felix Nathaniel "Angel" Villanueva Manalo II's house inside the Iglesia ni Cristo (INC) compound in Quezon City under Search Warrant No. 5326(7).

Several unlicensed firearms and ammunitions were allegedly discovered and confiscated.
Manalo, along with Victor EraAo Manalo Hemedez, Jonathan S. Ledesma, and others, were detained.
Several Informations were filed at the Office of the City Prosecutor of Quezon City (OCP-QC), including an illegal possession of firearms and ammunitions charge against Manalo under Section 28(b) of Republic Act No. 10591, docketed as Criminal Case No. R-QZN-17-03231-CR.
The original Information charged Manalo with possession of one M-16 rifle, one M1 carbine, and one 12-gauge shotgun without the necessary licenses.

Manalo filed a Motion for Reinvestigation which was granted by the Regional Trial Court (RTC) Branch 84 of Quezon City, directing a preliminary investigation by the OCP-QC.

The city prosecutor issued a Resolution affirming probable cause against Manalo and co-accused.
Police Chief Inspector Jun G. Fortunato filed a Motion for Partial Reconsideration seeking to upgrade the charge to Section 28(e) of RA 10591 due to the 12-gauge shotgun being loaded.

During the hearing of the Motion to Fix Bail, the prosecution filed a Motion to Admit Attached Amended Information to include the allegation that the 12-gauge shotgun bore seven live ammunitions.

The RTC Branch 84 issued a Joint Resolution denying the Motion to Fix Bail, granting the admission of the Amended Information, and setting arraignment and pre-trial.

Manalo filed a Motion for Reconsideration and a Motion to Inhibit against the presiding judge of RTC Branch 84. The RTC granted the Motion to Inhibit and ordered re-raffling.

The case was raffled to RTC Branch 85, whose judge voluntarily inhibited due to a related case.
The case was then re-raffled to RTC Branch 216.
RTC Branch 216 denied Manalo's Motion for Reconsideration.

On January 18, 2019, Manalo was arraigned but due to error, the original Information was read instead of the Amended Information.

Manalo, with counsel, pled not guilty to the original Information.
Upon realization of the error, the RTC directed the reading of the Amended Information.
Manalo refused to enter a plea, and the court entered a plea of not guilty on his behalf to the Amended Information.

Manalo filed a Motion to Quash the Amended Information, invoking double jeopardy, as he argued he was already arraigned and entered a plea not guilty under the original Information.

RTC Branch 216 denied the Motion to Quash, ruling the Amended Information was the correct and valid Information.
The court held that Manalo's plea to the original Information was improper as it was superseded by the Amended Information alleging qualified offense under Section 28(e), which could not be absorbed by the lesser Section 28(b) offense.
The reading of the Amended Information was a correction of inadvertence and did not result in conviction, acquittal, or dismissal without Manalo’s consent.

Manalo elevated the denial to the Court of Appeals (CA) which affirmed the RTC’s ruling, holding no violation of double jeopardy because first jeopardy had not attached.
Manalo filed a motion for reconsideration which was denied, then filed the instant petition before the Supreme Court.
The Office of the Solicitor General (OSG) argued that the Amended Information supersedes the original Information; hence, no valid plea could be derived from the original Information and no double jeopardy violation occurred.

Whether the Amended Information against Felix Nathaniel "Angel" Villanueva Manalo II should be quashed on the ground of double jeopardy.