Case Digest (G.R. No. L-4017)
Facts:
- The case involves the People of the Philippines (petitioners) and Jose C. Zulueta (respondent).
- On October 15, 1949, Zulueta was charged with malversation of public property.
- Zulueta was the Acting Chairman of the Surplus Property Commission.
- He was accused of allowing Beatriz Poblete to misappropriate 3,000 kegs of nails belonging to the Commission.
- The prosecution claimed Zulueta deceived Commissioner Angel Llanes into approving a low-priced sale of the nails, citing urgency for liquidation.
- Zulueta pleaded "not guilty" during his arraignment on November 24, 1949.
- An amended information was submitted on January 14, 1950, alleging conspiracy with Commissioner Llanes.
- Zulueta objected to the amended information, arguing it introduced substantial and prejudicial changes.
- The trial court admitted the amended information on February 28, 1950.
- After a failed motion for reconsideration, Zulueta filed a petition for certiorari in the Court of Appeals.
- The appellate court ruled in favor of Zulueta, prompting the People to file a petition for review.
Issue:
- (Unlock)
Ruling:
- The Supreme Court ruled that the amendment was substantial and prejudicial to the rights of the accused, affirming the Court of Appeals' decision to annul the order admitting the amended information.
- The Court held that certiorari was appropriate in this case, d...(Unlock)
Ratio:
- The Supreme Court emphasized that amendments to an information after a plea must not prejudice the defendant's rights.
- The amended information introduced a new theory of conspiracy, contradicting the original charge of deception, which was deemed substantial.
- This change altered the nature of the accusations, requiring Zulueta to prepare a different defense.
- The amendment b...continue reading
Case Digest (G.R. No. L-4017)
Facts:
The case involves the People of the Philippines as petitioners and Jose C. Zulueta as the respondent. The events leading to this case began on October 15, 1949, when an information was filed against Zulueta, charging him with malversation of public property. Zulueta served as the Acting Chairman of the Surplus Property Commission and was accused of allowing Beatriz Poblete to take and misappropriate 3,000 kegs of nails belonging to the Commission. The prosecution alleged that Zulueta had deceived Commissioner Angel Llanes into approving a sale of these nails at a significantly low price, claiming urgency to expedite the liquidation of surplus properties.
Zulueta was arraigned on November 24, 1949, and pleaded "not guilty." On January 14, 1950, the prosecution submitted an amended information, which included additional allegations that Zulueta acted in conspiracy with Commissioner Llanes, who was also charged with malversation regarding the same public property. Zulueta objected to the admission of the amended information, arguing that it introduced substantial and prejudicial changes to the original charges. The trial court admitted the amended information on February 28, 1950. Following a failed motion for reconsideration, Zulueta filed a petition for certiorari in the Court of Appeals to annul the order admitting the amended information. The appellate cou...