Case Summary (G.R. No. 265585)
Antecedents of the Case
The police search, conducted under Search Warrant No. 5326(7), led to the seizure of various firearms, resulting in Manalo and several others being detained and charged with illegal possession under Republic Act No. 10591. This included accusations of possessing an M-16 rifle, an M1 carbine, and a shotgun without the necessary legal permits.
Motion for Reinvestigation
Following the filing of criminal charges, Manalo initiated a Motion for Reinvestigation, which the Regional Trial Court (RTC), Branch 84 of Quezon City, granted. The RTC directed the Office of the City Prosecutor of Quezon City to conduct a preliminary investigation, leading to the confirmation of probable cause against Manalo and his co-accused.
Amended Information and Legal Proceedings
A significant development in the case occurred when the prosecution sought to amend the original Information for the charge against Manalo. They argued an inadvertent omission occurred in detailing that one of the seized firearms was loaded with ammunition, which elevated the severity of the charge. The RTC Branch 84 granted this amendment, causing subsequent legal disputes including a denial of bail and motions to reconsider filed by Manalo.
Double Jeopardy Argument
Manalo argued that entering a plea of not guilty under the original Information constituted double jeopardy, as he was being prosecuted again under an Amended Information. The RTC denied his Motion to Quash and held that the Amended Information was valid since the original was superseded and no valid plea had been established against it. The court clarified that double jeopardy claims require a valid prior prosecution, which was not demonstrated in this circumstance.
Appeal to the Court of Appeals
Manalo's appeal of the RTC's decisions was taken to the Court of Appeals (CA), which upheld the RTC's ruling, concluding that the prerequisites for double jeopardy were not met. The CA identified that a valid plea had not been registered since the original Information was invalidated with the filing of the Amended Information.
Supreme Court's Conclusion
The Supreme Court affirmed the CA's decision, further clarifying the rules of double jeopardy as defined in the Rules of Court. It noted that double jeopardy attaches only when there is a valid indictment, a valid plea, and a termination of the previous case without the accused's express consent. The Petition by Manalo was ultimately denied, allowing the RTC to proceed with the arraignment under the Amended Information.
Clarifica
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Background and Procedural History
- On March 2, 2017, police conducted a search under Search Warrant No. 5326(7) at petitioner Manalo's house inside the Iglesia ni Cristo compound in Quezon City.
- Several unlicensed firearms and ammunition were allegedly seized.
- Manalo, along with others, was detained and charged with illegal possession of firearms under Section 28(b) of R.A. No. 10591 (Criminal Case No. R-QZN-17-03231-CR).
- The Information was later amended to include the fact that one 12-gauge shotgun was loaded, qualifying the offense under Section 28(e) of R.A. No. 10591.
- Movements for reinvestigation, bail fixing, amendment of Information, filiation to different RTC branches, motions for reconsideration, and motions to inhibit judges characterized the complex procedural history.
- Manalo filed a Motion to Quash the Amended Information alleging double jeopardy after arraignment issues where he was first arraigned under the original Information and later under the amended Information.
- The RTC Branch 216 denied the Motion to Quash, ruling the Amended Information as the correct and valid complaint.
- The Court of Appeals affirmed the RTC ruling.
- Manalo elevated the decision to the Supreme Court through a Petition for Review on Certiorari.
Facts of the Case
- Manalo was accused of possession of firearms without license or permit - specifically: a) One M-16 Colt AR-15 rifle. b) One M1 carbine. c) One 12-gauge Action shotgun with seven live ammunitions (added later in Amended Information).
- The police filed a Motion for Partial Reconsideration to upgrade the charge due to loaded ammunition.
- The Amended Information was filed and admitted during the proceedings.
- Arraignment was initially conducted on the original Information by inadvertence.
- Upon discovering the error, the court ordered reading of the Amended Information.
- Manalo refused to enter a plea