Title
People vs. Zulueta
Case
G.R. No. L-4017
Decision Date
Aug 30, 1951
The Supreme Court annulled the admission of amended information in the conspiracy case against Zulueta and Llanes for illegal nail sales, emphasizing the necessity of properly informing the accused of the charges.
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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

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