Case Digest (G.R. No. L-21528)
Facts:
Rosauro Reyes v. The People of the Philippines, G.R. Nos. L-21528 & L-21529, March 28, 1969, the Supreme Court En Banc, Makalintal, J., writing for the Court.The petitioner, Rosauro Reyes, a former civilian employee of the Navy Exchange at Sangley Point whose services were terminated on May 6, 1961, led a demonstration on June 6, 1961, in front of the main gate of the U.S. Naval Station at Sangley Point. The demonstration involved about 20–30 persons carrying placards with hostile statements directed at Agustin Hallare and a certain Frank Nolan. The naval base commander summoned Col. Patricia Monzon, the Philippine Military Liaison Officer, who spoke with Reyes and others and advised them to demonstrate in front of Hallare’s residence; they refused, saying they wanted those in the station to see their protest but promised no violence.
When Hallare learned of the demonstration he sought Col. Monzon’s protection; Monzon escorted Hallare and companions out of the base and, after slowing to let Hallare view the demonstrators, proceeded to his residence. The demonstrators followed in three jeeps, parked twice in front of Hallare’s house, and Reyes posted himself at the gate. With his right hand in his pocket and left holding the gate, Reyes loudly shouted, among other things, “Agustin, putang ina mo. Agustin, mawawala ka. Agustin lumabas ka, papatayin kita.” Frightened, Hallare remained inside his house.
On July 24 and 25, 1961, Reyes was charged in the Municipal Court of Cavite City in Criminal Case No. 2594 with grave threats (Art. 282, Revised Penal Code) and in Criminal Case No. 2595 with grave oral defamation (Art. 358, Revised Penal Code). Reyes pleaded not guilty to both informations. Prior to trial the prosecution moved to amend the information for grave threats by deleting the word “orally”; the trial court allowed the amendment over defense objection, and the joint trial proceeded without requiring a new plea to the amended information. The municipal court convicted Reyes of both offenses and imposed the penalties described in the opinion.
Reyes appealed to the Court of Appeals, which affirmed the convictions; a motion for reconsideration was denied. Reyes then brought the case to the Supreme Court by petition for certiorari (appeal by certiorari) challenging, among others, t...(Pro-only)
Issues:
- Was the amendment of the information (deleting the word “orally”) after arraignment permissible under the rules governing amendments to informations?
- Did the trial court commit error by proceeding without requiring the accused to enter a new plea to the amended information?
- Could petitioner be validly convicted of both grave threats and grave oral defamation for the same course of conduct, or would that result in impermissible multiple punishment?
- Did the evidence support conviction for the crime of grave threats rather than only light threats?
- Did the evidence support conviction for grave oral defamation rather than trea...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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