G.R. No. 265585 , April 15, 2024
FELIX NATHANIEL “ANGEL” VILLANUEVA MANALO II, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

On March 2, 2017, police officers conducted a search at the house of Felix Nathaniel “Angel” Villanueva Manalo II (Manalo) inside an Iglesia ni Cristo compound in Quezon City, leading to the alleged discovery of unlicensed firearms and ammunition. An Information was filed against Manalo for illegal possession of firearms under Section 28(b) of Republic Act No. 10591 . The prosecution later filed a Motion to Admit Attached Amended Information to correct an inadvertence, alleging that one of the firearms, a 12-gauge shotgun, was loaded with ammunition, which would qualify the offense under Section 28(e) of the same law. The Regional Trial Court (RTC) Branch 84 granted the motion to admit the Amended Information. The case was eventually re-raffled to RTC Branch 216. During arraignment on January 18, 2019, the original Information was mistakenly read to Manalo, to which he pleaded not guilty. Upon discovery of the error, the court directed the reading of the Amended Information. Manalo refused to enter a new plea, arguing he had already been arraigned. The court then entered a plea of “not guilty” on his behalf. Manalo filed a Motion to Quash the Amended Information, arguing that his rearraignment violated his right against double jeopardy. The RTC Branch 216 denied the motion, ruling that the original Information was insufficient and invalid, and that the valid plea was the one entered by the court for the Amended Information. The Court of Appeals affirmed the RTC’s ruling. Manalo elevated the case to the Supreme Court via a Petition for Review on Certiorari.

ISSUE

Whether the rearraignment of Manalo under the Amended Information, after he had already pleaded not guilty to the original Information, violated his constitutional right against double jeopardy.

RULING

No. The Supreme Court denied the petition and affirmed the rulings of the lower courts. The Court held that the right against double jeopardy was not violated. For double jeopardy to attach, the following elements must concur: (1) a valid indictment, (2) before a court of competent jurisdiction, (3) the defendant has pleaded to the charge, and (4) the defendant was acquitted, convicted, or the case was dismissed or otherwise terminated without his express consent. In this case, the first jeopardy had not attached. The original Information was superseded and rendered without legal effect by the validly admitted Amended Information. Consequently, Manalo’s plea to the original Information was invalid, as it was based on a void accusatory pleading. The valid plea was the “not guilty” plea entered by the court on his behalf for the Amended Information. The re-reading of the Amended Information was a mere correction of a clerical error and did not constitute a second jeopardy, as there was no valid first jeopardy. The proceedings continued under one continuous trial for a single offense.