G.R. No. 1478 , February 16, 1904
THE UNITED STATES, complainant-appellee, vs. JUAN DE LA CRUZ, ET AL., defendants-appellants.

FACTS:
The defendants were convicted in the Court of First Instance for the crime of brigandage, as defined and punished under Section 1 of Act No. 518 of the Philippine Commission, and were each sentenced to twenty years of imprisonment. During the trial, an amendment to the complaint was allowed by the court before the presentation of evidence for the defense. The defendants appealed the conviction, contending that the amendment to the complaint constituted a fatal error under Section 10 of General Orders No. 58, as it allegedly prejudiced their substantial rights.

ISSUE:
Whether the amendment to the complaint made during the trial constitutes a reversible error that prejudiced the essential rights of the defendants.

RULING:
No, the amendment did not constitute a reversible error. The Supreme Court affirmed the conviction. The Court held that the amendment did not prejudice any essential rights of the defendants for two reasons: first, it did not affect the essence of the crime charged but merely pertained to an accidental detail of the offense; and second, it did not deprive the accused of an opportunity to present evidence in relation to the amendment had they so desired. Therefore, the allowance of the amendment was not a fatal error. The sentence appealed from was affirmed, with costs imposed upon the defendants.