GR 151785; (December, 2007) (Digest)
G.R. No. 151785 , December 10, 2007
SUSAN FRONDA-BAGGAO, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.
FACTS
In 1989, the Provincial Prosecutor of Abra filed four separate Informations for simple illegal recruitment against petitioner Susan Fronda-Baggao and Lawrence Lee. The cases were archived as petitioner eluded arrest for over a decade. Upon her arrest in July 1999, the prosecutor moved to amend the four separate Informations into a single Information for the graver offense of Illegal Recruitment in Large Scale. The trial court initially denied the motion but later granted reconsideration, admitting the amended Information and ordering the case transferred to a special criminal court.
Petitioner challenged this amendment before the Court of Appeals via a petition for certiorari and prohibition, arguing it violated procedural rules and her substantial rights. The appellate court denied her petition and subsequent motion for reconsideration, prompting this Petition for Review on Certiorari.
ISSUE
Whether the trial court correctly allowed the amendment of four separate Informations for simple illegal recruitment into a single Information for Illegal Recruitment in Large Scale before the petitioner had entered her plea.
RULING
The Supreme Court affirmed the Court of Appeals and upheld the amendment. The legal logic rests on Section 14, Rule 110 of the Revised Rules on Criminal Procedure, which permits a complaint or information to be amended in form or substance without leave of court before the accused enters a plea. Since petitioner had not been arraigned or pleaded when the amendment was made, the provision squarely applied. The Court rejected petitioner’s argument that the rule contemplates amendment of only a single information, noting such a restrictive interpretation would lead to absurdity and frustrate the rules’ objective of a just, speedy, and inexpensive disposition under Section 6, Rule 1. Precedent (Galvez v. Court of Appeals) allows amendment of multiple informations before arraignment.
The Court also dismissed petitioner’s claim of prejudice to her substantial rights, particularly her right to bail. The protective clause against prejudice under Section 14 applies only after a plea has been entered, a stage not yet reached. Therefore, the amendment from four separate charges to one consolidated charge for a graver offense was procedurally sound and did not violate petitioner’s rights at that pre-arraignment juncture.