Facts:

• Ceferino M. Regala is the petitioner against the Judge of the Court of First Instance of Bataan.
• On May 20, 1946, Regala was informed of a murder complaint against him and pleaded not guilty.
• The original complaint named him as the sole accused, with Wenceslao Cruz and Conrado Manalac as witnesses.
• On June 6, 1946, the Provincial Fiscal filed an amended complaint, adding Cruz and Manalac as co-accused, alleging conspiracy.
• The court admitted the amended complaint, and the Provincial Fiscal moved to dismiss charges against Cruz and Manalac to use them as prosecution witnesses.
• The judge granted the motion on the same day.
• Regala filed a notice of appeal on June 14, which was denied on June 19.
• A motion for reconsideration was also denied on July 11.
• Regala argued that the denial of his appeal harmed his substantial rights and claimed the judge's order was null due to lack of approval from the Commission on Appointments.
• He sought a writ of certiorari to annul the orders of June 6 and July 11, 1946.

Issue:

• (Unlock)

Ruling:

• The Supreme Court ruled that the trial court did not exceed its jurisdiction in allowing the amendment of the complaint.
• The Court held that the amendment was merely formal a...(Unlock)

Ratio:

• The Supreme Court reasoned that a court with jurisdiction over a criminal case can decide all incidental questions, including the sufficiency of a complaint.
• An erroneous decision on such matters does not equate to acting beyond jurisdiction.
• The amendment allowed by the trial court was deemed formal, not altering the essence of the crime charged.
• The nature of the crime...continue reading