G.R. No. L-21528 - Reyes vs. People

Rosauro Reyes, petitioner, was a former civilian employee of the Navy Exchange at Sangley Point, Cavite City. His services were terminated on May 6, 1961.
On June 6, 1961, Reyes led a demonstration of about 20 to 30 persons in front of the main gate of the U.S. Naval Station at Sangley Point carrying placards with threatening and insulting statements against Agustin Hallare and Frank Nolan.
The base commander, Capt. McAllister, requested Col. Patricia Monzon, Philippine Military Liaison Officer, to meet the demonstrators. Reyes and Luis Buenaventura explained the protest targeted Hallare and Nolan for Reyes' dismissal, but they assured no violence was intended.
Hallare, present in the naval station, became apprehensive and sought Col. Monzon’s protection, who escorted him out in his car. The demonstrators followed in a motorcade to Hallare’s residence.
Upon arrival, Reyes shouted repeated threats at Hallare, such as "Agustin, putang ina mo," "Agustin, mawawala ka," and "Agustin lumabas ka, papatayin kita." Hallare remained inside, frightened.
Reyes was charged with grave threats (Criminal Case No. 2594) and grave oral defamation (Criminal Case No. 2595) based on these acts.

The information for grave threats initially included the word "orally," which the prosecution moved to delete after arraignment, arguing it was a mere formality and to conform evidence. The court allowed the amendment over defense objection.
Reyes pleaded not guilty to both charges; the trial proceeded jointly.
Reyes was convicted by the municipal court of Cavite City, sentenced to four months and ten days of arresto mayor and a P300 fine for grave threats, and sentenced to an indeterminate penalty ranging from four months arresto mayor to one year eight months prision correctional plus moral damages of P800 for grave oral defamation.
The Court of Appeals affirmed the convictions; Reyes appealed by certiorari to the Supreme Court.

The deletion of the word "orally" in the grave threats charge was improper as it constituted a substantial amendment after arraignment without a new plea.
Trial on the grave threats case proceeded without Reynolds entering a plea to the amended information.
Reyes was unlawfully convicted of two offenses when only one could be punished, risking double jeopardy.
The evidence only supported light threats, not grave threats.
The evidence only supported simple slander, not grave oral defamation.

Whether or not the amendment of the information by deleting the word "orally" after arraignment was proper and prejudicial to the accused.
Whether the trial court erred in proceeding with the trial on the amended charge without requiring the accused to enter a new plea.
Whether Reyes could be convicted of two offenses or was protected against double jeopardy.
Whether the evidence sufficiently established the crime of grave threats or only light threats.
Whether the evidence supported the conviction for grave oral defamation or only simple slander.