People v. Manalo
REITERATIONFacts
The Antecedents: Police officers conducted a search and seizure operation at the house of Felix Nathaniel "Angel" Villanueva Manalo II (Manalo) inside the Iglesia ni Cristo (INC) compound in Quezon City, pursuant to Search Warrant No. 5326(7). Unlicensed firearms and ammunition were allegedly discovered and confiscated. Subsequently, Manalo and others were charged with illegal possession of firearms and ammunition under Section 28(b) of Republic Act No. 10591. Procedural History: Manalo filed a Motion for Reinvestigation, which was granted. The city prosecutor affirmed the finding of probable cause. The prosecution filed a Motion to Admit Attached Amended Information, seeking to allege that one of the firearms was loaded with ammunition, thus qualifying the offense under Section 28(e) of Republic Act No. 10591. The Regional Trial Court (RTC) Branch 84 granted the motion to amend the information and denied Manalo's Motion to Fix Bail. The case was re-raffled twice due to inhibitions, eventually landing with RTC Branch 216. Meanwhile, Manalo was arraigned under the original Information, to which he pleaded not guilty. Upon discovery of the error, the RTC Branch 216 directed the reading of the Amended Information. Manalo refused to enter a plea, but the RTC entered a plea of "not guilty" on his behalf. Manalo filed a Motion to Quash the Amended Information, arguing double jeopardy. The RTC denied the motion, holding that the Amended Information was the only valid one and Manalo's plea to the original Information was invalid. The Court of Appeals (CA) affirmed the RTC's ruling, finding that the elements of double jeopardy had not attached. The Petition: Manalo contended that the prosecution was bound by his initial plea, that the requisites for double jeopardy were present, and that rearraignment was not permissible in this case. The Office of the Solicitor General argued that the Amended Information superseded the original, rendering the latter without legal effect, and thus no valid plea could be derived from it.
Issue(s)
Whether the Amended Information filed against petitioner Felix Nathaniel "Angel" Villanueva Manalo II should be quashed on the ground of double jeopardy, considering the elements required for double jeopardy to attach.
Ruling
The Petition is denied. The assailed Decision and Resolution of the Court of Appeals are affirmed. The Amended Information in Criminal Case No. R-QZN-17-03231-CR is admitted. The Regional Trial Court, Branch 216, Quezon City is ordered to proceed with the arraignment and pre-trial of Felix Nathaniel "Angel" Villanueva Manalo II with dispatch.
Ratio Decidendi
On the issue of double jeopardy: The Court held that the petitioner's insistence on double jeopardy was misplaced because the elements for the first jeopardy to attach were not established. Specifically, the fourth and fifth elements were absent: it was not shown that the petitioner had entered a valid plea on the prior charge, nor that he had been acquitted or convicted, or that the case was dismissed or terminated without his express consent. The Court reiterated the requisites for double jeopardy, which include a valid indictment, a competent court, arraignment, a valid plea, and termination of the case without the accused's consent. In this case, the initial arraignment was based on an information that had already been superseded by an amended information, rendering the original information legally nonexistent. Therefore, any plea entered based on the original information could not be considered a valid plea for the purposes of attaching double jeopardy. The Court emphasized that the rearraignment under the original information, which had been superseded by the amended information, was properly declared null and void, and no valid judgment could have been rendered. The prompt action of the prosecution to correct the inadvertent reading of the original information and their motion to re-read the amended information demonstrated the State's clear intention to prosecute under the amended charge. The Court found it would be unfair to penalize the prosecution for a mistake in the reading of the information that it did not commit. Furthermore, the re-reading of the amended information did not result in the petitioner's conviction or acquittal, nor did it operate to dismiss or terminate the case without his consent; it was merely a correction of an inadvertence within a continuous trial over one offense. The Court cited Binabay v. People of the Phil., which held that when an accused is inadvertently rearraigned under an original information that had been superseded by an amended information, the original information is legally nonexistent, and the rearraignment and plea are null and void.
Main Doctrine
The filing of an amended information and subsequent rearraignment does not violate the right against double jeopardy if the original information was legally nonexistent or had been superseded, and no valid plea was entered therein, especially when the error in reading the original information was promptly corrected.