G.R. No. 249121 - Manalo II vs. People

Case Summary (G.R. No. 249121)

Background and Charges

On March 2, 2017, police conducted a search of petitioner’s residence inside the Iglesia Ni Cristo compound in Quezon City pursuant to a valid Search Warrant. Several unlicensed firearms and ammunition were found. The Office of the City Prosecutor (OCP) of Quezon City conducted an inquest the following day and, finding probable cause, recommended filing charges against petitioner and his companions for violations of R.A. No. 10591, specifically illegal possession of firearms and ammunition. The OCP ordered their release subject to approval.

Petitioner was charged before the RTC with illegal possession of firearms under Section 28(b) of R.A. No. 10591, which prescribes the penalty of reclusion temporal to reclusion perpetua for possession of three or more small arms or Class-A light weapons without a license. Petitioner moved for reinvestigation and to fix bail after the OCP recommended no bail.

RTC Proceedings on Amended Information and Bail

The prosecution filed a Motion to Admit Amended Information on October 9, 2017, which added charges under Section 28(e) in relation to Section 28(b) of R.A. No. 10591—an offense punishable by reclusion perpetua to death—and indicated that one firearm was loaded with live ammunition. The RTC, on November 20, 2017, issued a Joint Resolution granting the motion to admit the Amended Information and denying petitioner’s motion to fix bail, reasoning: (1) the rules allow amendments to information before plea without leave of court; (2) the amended information bore the signature of the City Prosecutor (Donald T. Lee), validating the approval despite initial procedural issues; and (3) petitioner was charged with a capital offense, which is generally non-bailable as a matter of right.

Petitioner filed motions contesting the validity of the amended information due to alleged lack of City Prosecutor’s prior written approval and for reconsideration of the denial of bail. Motions to inhibit judges were also granted, leading to re-raffling of the case. A different RTC Branch, Branch 216, issued an Omnibus Order on October 30, 2018, denying reconsideration and reaffirming the validity of the Amended Information and denial of bail, citing that the belated signature of the City Prosecutor validated it and reaffirming that R.A. No. 9346 (abolishing death penalty) does not affect the classification of crimes regarding penalty ranges.

Court of Appeals Decision

Petitioner filed a Petition for Certiorari before the CA seeking to annul the RTC’s Joint Resolution and Omnibus Order concerning the amended information and bail. On August 30, 2019, the CA dismissed the petition, affirming the RTC rulings. The CA held that: (1) any defect in the amended information due to absent signature was cured by the subsequent submission of the signed document before arraignment, consistent with procedural rules allowing amendments prior to plea; and (2) petitioner was lawfully denied bail as a matter of right because the offense charged under Section 28(e) of R.A. No. 10591 carries a penalty which is a capital offense (reclusion perpetua to death).

Issues Presented

Whether the CA erred in upholding the validity of the Amended Information charging petitioner with a capital offense despite initial absence of City Prosecutor’s signature.
Whether the CA erred in affirming the RTC’s denial of bail as a matter of right to petitioner.

Legal Analysis: Validity of the Amended Information

Under Section 14, Rule 110 of the Rules of Court, the prosecution is permitted to amend a complaint or information in form or substance without leave of court at any time before the accused enters a plea. Amendments that downgrade the offense or exclude accused require motion and leave of court. Prior to arraignment, the accused’s substantial rights are not yet implicated, thus amendments—even significant ones—are allowed.

The Court en banc reconfirmed in People v. Villa Gomez that absence of the City Prosecutor’s signature on the information is a formal defect, not affecting jurisdiction over the person or subject matter. Formal defects can be cured by subsequent approval or submission of properly signed pleadings before arraignment.

In this case, although the original and first filed amended information lacked the City Prosecutor’s signature, a second copy of the amended information bearing such signature was submitted before arraignment. Therefore, the amended information was validly filed and constituted a sufficient basis for indictment. Petitioner’s reliance on prior jurisprudence treating lack of signature as a jurisdictional defect is unavailing because such rulings are not substantive law and cannot be invoked to disregard the current and controlling doctrine.

Legal Analysis: Bail as a Matter of Right

The Court emphasized that bail rights depend on the nature of the offense charged and the applicable penalty range. The amended information charged petitioner under Section 28(e) in relation to Section 28(b) of R.A. No. 10591, a non-bailable offense carrying reclusion perpetua to death. Despite R.A. No. 9346 abolishing the death penalty, the classification of the crime and its penalty severity remain, and this does not automatically entitle the accused to bail as a matter of right.

Contrary to petitio

Case Syllabus (G.R. No. 249121)

Case Background and Procedural History

Petitioner Felix Nathaniel "Angel" Villanueva Manalo II filed an Appeal by Certiorari seeking to reverse the Court of Appeals (CA) decision dated August 30, 2019, which upheld rulings of the Regional Trial Court (RTC) of Quezon City.
The RTC decisions involved Criminal Case Nos. Q-17-03230-CR (Direct Assault with Frustrated Murder), Q-17-03231-CR (Violation of Section 28(b) of R.A. 10591 - Illegal Possession of Firearms and Ammunition), and Q-17-03232-33-CR (Violation of Sections 28(g) and (h) of R.A. 10591).
The petitioner contested: (1) the RTC’s November 20, 2017 Joint Resolution granting the Motion to Admit Attached Amended Information and admitting the Amended Information; and (2) the RTC’s denial of his Motion to Fix Bail, and the denial of his Motion for Reconsideration on October 30, 2018.

Facts of the Case

On March 2, 2017, police officers conducted a search warrant inside petitioner’s house within the Iglesia Ni Cristo Compound in Quezon City and found several unlicensed firearms and ammunition.
The Office of the City Prosecutor (OCP) conducted an inquest and issued a Resolution on March 3, 2017, recommending the filing of Information for violation of R.A. No. 10591 against petitioner and his companions for illegal possession of firearms.
Petitioner was charged with violation of Section 28(b) of R.A. No. 10591 (Illegal Possession of Firearms and Ammunition) under an Information filed on March 6, 2017.
The OCP recommended “no bail,” prompting petitioner to file motions for reinvestigation and to fix bail.
Subsequent OCP Resolutions maintained probable cause and recommended continuing prosecution.
On October 9, 2017, the OCP filed a Motion to Admit Attached Amended Information adding charges including a violation of Section 28(e) to increase penalty aggravation.
RTC Branch 84 issued a Joint Resolution on November 20, 2017 that admitted the Amended Information and denied petitioner’s motion to fix bail.
Petitioner filed a Motion for Reconsideration and Manifestation alleging tampering with the Amended Information due to the absence of City Prosecutor’s signature initially.
After judicial recusals, the case was re-raffled to RTC Branch 216 which denied the Motion for Reconsideration on October 30, 2018.
The CA dismissed petitioner’s Petition for Certiorari on August 30, 2019, affirming the RTC rulings.

Issues Presented

Whether the Court of Appeals erred in not finding grave abuse of discretion by the RTC in upholding the validity of the Amended Information charging petitioner with a capital offense.
Whether the Court of Appeals erred in not finding grave abuse of discretion by the RTC in holding that petitioner is not entitled to bail as a matter of right.

Legal Context and Relevant Laws

Republic Act No. 10591 (“Comprehensive Law on Firearms and Ammunition”) penalizes unlawful possession; Section 28(b) prescribes reclusion temporal to reclusion perpetua for possession of three or more small arms.
Section 28(e) imposes a penalty one degree higher if the firearm was in specified conditions, including being loaded.
Rule 110, Section 14 of the Rules of Court allows complaints or informations to be amended without leave of court before plea, including amendments in form or substance.
People v. Villa Gomez clarified that lack of a signature and approval by the chief state, provincial, or city prosecutor on an Information is a formal defect that does not affect the court’s jurisdiction.
R.A. No. 9346 abolished the death penalty but does not a