Case Summary (G.R. No. 183619)
Factual Background
On March 2, 2017, police executed Search Warrant No. 5326(7) at petitioner’s residence inside the compound of Iglesia ni Cristo in Quezon City, where they allegedly recovered several unlicensed firearms and ammunition. Petitioner and several others were detained and multiple Informations were filed with the Office of the City Prosecutor of Quezon City, including Criminal Case No. R-QZN-17-03231-CR charging petitioner with illegal possession of firearms under Section 28(b) of Republic Act No. 10591.
Accusatory Allegations and Amended Information
The original Information accused petitioner of possessing three firearms listed by serial number and alleged they were without the necessary license. Subsequent to a Motion for Reinvestigation and a finding of probable cause by the city prosecutor, the prosecution moved to admit an Amended Information to allege that the 12-gauge action shotgun was “Loaded with seven (7) live ammunitions,” thereby invoking the qualifying provision under Section 28(e) of Republic Act No. 10591.
Pretrial Proceedings and Judicial Re‑raffling
The RTC, Branch 84, initially granted the prosecution’s motion to admit the Amended Information, denied petitioner’s motion to fix bail, and set arraignment and pre‑trial. Motions to inhibit and other procedural steps led to re‑raffling of the case from Branch 84 to Branch 85 and ultimately to Branch 216, where an Omnibus Order and further rulings on motions were issued.
Arraignment Events
On January 18, 2019, during arraignment, the trial court read the contents of the original Information to petitioner by inadvertence; petitioner, through counsel, pleaded not guilty to that original Information. The error was then discovered, the prosecution moved for the re‑reading of the Amended Information, and when the Amended Information was read petitioner refused to enter a plea, asserting he had already pleaded not guilty to the original Information; the court thereupon entered a plea of “not guilty” on petitioner’s behalf to the Amended Information.
Motion to Quash and Trial Court Rulings
Petitioner filed a Motion to Quash the Amended Information on the ground of double jeopardy under Rule 117, Section 3(i), asserting that his initial plea to the original Information bound the prosecution and that rearraignment under the Amended Information placed him twice in jeopardy for the same offense. RTC, Branch 216 denied the Motion to Quash and denied reconsideration, ruling that the Amended Information was the only valid information, that the original Information had been superseded, and that the re‑reading corrected an inadvertent error without effecting a prior valid plea or terminating the prosecution.
Court of Appeals Decision
Petitioner sought certiorari relief in the Court of Appeals, which affirmed the RTC. The CA held that the elements for attachment of the first jeopardy were not satisfied because petitioner had not entered a valid plea to the superseding Amended Information, and therefore the constitutional protection against double jeopardy had not been violated. The CA found no grave abuse of discretion in the RTC’s rulings.
Issue Presented to the Supreme Court
The single dispositive issue before the Supreme Court was whether the Amended Information against petitioner should be quashed on the ground that his arraignment and plea to the original Information operated to attach the first jeopardy and thus bar prosecution under the Amended Information by reason of double jeopardy.
Supreme Court Disposition
The Supreme Court denied the Petition for Review on Certiorari. The Court affirmed the CA’s July 13, 2022 Decision and December 19, 2022 Resolution in CA‑G.R. SP No. 166960, admitted the Amended Information in Criminal Case No. R‑QZN‑17‑03231‑CR, and ordered RTC, Branch 216, Quezon City to proceed with arraignment and pre‑trial with dispatch.
Majority Legal Reasoning
The Court analyzed Rule 117, Section 7 and confirmed that the requisites for double jeopardy require, among others, that a first jeopardy must have attached by reason of a valid indictment, before a competent court, after arraignment, and when a valid plea had been entered and thereafter the case had been terminated without the accused’s express consent. The Court concluded that petitioner did not establish that a valid plea had been entered to the subsisting charge or that any prior jeopardy had been validly terminated. The Court relied on precedent in holding that an original Information superseded by an Amended Information was legally nonexistent and that the re‑reading of the Amended Information corrected an inadvertence; the State’s expressed intention to proceed under the Amended Information and the trial court’s inadvertent reading of the superseded original Information precluded application of double jeopardy.
Precedents and Doctrinal Application
The Court cited earlier decisions distinguishing situations where a superseded original Information is a nullity and where an arraignment under a nonexistent instrument yield
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Parties and Procedural Posture
- Felix Nathaniel "Angel" Villanueva Manalo II, Petitioner, was charged in the Regional Trial Court with unlawful possession of firearms and ammunition and later faced an amended charge alleging a qualified offense under Republic Act No. 10591.
- People of the Philippines, Respondent, prosecuted the case through the Office of the City Prosecutor, Quezon City.
- Petitioner filed a Motion to Quash the Amended Information on the ground of double jeopardy, which the RTC denied and the Court of Appeals affirmed, prompting this Petition for Review on Certiorari.
Key Facts
- Police executed a search and seizure at petitioner’s house inside the Iglesia ni Cristo compound in Quezon City on March 2, 2017, and allegedly confiscated unlicensed firearms and ammunition.
- The original Information charged petitioner with possession of three firearms without alleging that any firearm was loaded.
- The prosecution moved to admit an Amended Information to allege that a 12-gauge action shotgun was "Loaded with seven (7) live ammunitions."
- At arraignment on January 18, 2019, the original Information was inadvertently read to petitioner, and with counsel he entered a plea of not guilty to the original Information.
- The court then ordered the Amended Information to be read, petitioner refused to enter a plea, and the RTC entered a plea of "not guilty" on petitioner’s behalf to the Amended Information.
Lower Court Proceedings
- The Office of the City Prosecutor found probable cause and filed the Information in Criminal Case No. R-QZN-17-03231-CR.
- The RTC, Branch 84, granted the prosecution's motion to admit the Amended Information and denied petitioner’s Motion to Fix Bail.
- The case was re-raffled from Branch 84 to Branch 85, and subsequently to Branch 216 after recusals and inhibitions.
- RTC, Branch 216, denied petitioner’s Motion to Quash the Amended Information and denied reconsideration.
- The Court of Appeals, in CA-G.R. SP No. 166960, affirmed the RTC’s denial of the Motion to Quash and denied petitioner’s motion for reconsideration.
Issue Presented
- Whether the Amended Information filed against petitioner should be quashed on the ground of double jeopardy.
Arguments of the Parties
- Petitioner argued that the prosecution was bound by his initial plea to the original Information and that all requisites for double jeopardy were present when the Amended Information was later read.
- The Office of the Solicitor General (OSG) argued that the Amended Information superseded the original Information and that no valid plea had been entered to the Amended Information such that jeopardy had not attached.