G.R. No. 249121, August 02, 2023
Felix Nathaniel “Angel” Villanueva Manalo II, Petitioner, vs. People of the Philippines, Respondent.

FACTS

On March 2, 2017, police officers conducted a search in petitioner’s house inside the Iglesia Ni Cristo Compound by virtue of a Search Warrant and found several unlicensed firearms and ammunition. The Office of the City Prosecutor (OCP) of Quezon City recommended the filing of an Information for violation of Republic Act No. 10591 (Illegal Possession of Firearms) against petitioner. The OCP made a “no bail” recommendation. Petitioner filed a Motion for Reinvestigation and a Motion to Fix Bail. Before the Regional Trial Court (RTC) could act, the OCP issued another Resolution affirming its finding of probable cause. Subsequently, a prosecution witness filed a Motion for Partial Reconsideration before the OCP, seeking, among others, to charge petitioner with the complex crime of Direct Assault with Frustrated Murder and to amend the Informations. On October 9, 2017, the OCP filed with the RTC a Motion to Admit Attached Amended Information, which added the phrase “IN REL. TO SEC. 28(e)” to the original charge under Section 28(b) of R.A. No. 10591. On November 20, 2017, the RTC, Branch 84, issued a Joint Resolution denying petitioner’s Motion to Fix Bail and admitting the Amended Information. Petitioner filed a Manifestation alleging that the original Amended Information did not contain the signature and approval of the City Prosecutor, rendering it void under the doctrine of People v. Garfin. He later filed a Motion for Reconsideration. The case was re-raffled to Branch 216, which, on October 30, 2018, issued an Omnibus Order denying petitioner’s Motion for Reconsideration. Petitioner filed a Petition for Certiorari before the Court of Appeals (CA), which, on August 30, 2019, dismissed the petition and affirmed the RTC’s Joint Resolution and Omnibus Order. Petitioner elevated the case to the Supreme Court via an Appeal by Certiorari.

ISSUE

The core issue is whether the Court of Appeals erred in affirming the RTC’s orders which: (1) admitted the Amended Information that initially lacked the City Prosecutor’s signature, and (2) denied petitioner’s Motion to Fix Bail based on the amended charge being a capital offense.

RULING

The Supreme Court denied the petition and affirmed the assailed CA Decision. The Court held:
1. On the Validity of the Amended Information: The Amended Information was validly admitted. The initial lack of the City Prosecutor’s signature was a formal defect that was subsequently cured when the prosecution submitted a copy bearing the City Prosecutor’s signature and approval. The amendment was made before the accused entered his plea, which is allowed under Section 14, Rule 110 of the Rules of Court. The amendment did not prejudice petitioner’s substantial rights as it did not charge a new or different offense; it merely specified the relation to another subsection of the same law (R.A. No. 10591).
2. On the Denial of the Motion to Fix Bail: The denial of bail was proper. The Amended Information charged petitioner with Illegal Possession of Firearms under Section 28(b) in relation to Section 28(e) of R.A. No. 10591. Section 28(e) penalizes the possession of a “loose firearm,” which is defined under the law as including an unregistered firearm. The penalty for this offense, when the firearm is a rifle, is reclusion perpetua to reclusion temporal. Since the charge is punishable by reclusion perpetua, it is a capital offense. Under the Rules, an accused charged with a capital offense is not entitled to bail as a matter of right. The Court clarified that the prohibition against the imposition of the death penalty under R.A. No. 9346 does not affect the classification of crimes; an offense remains capital if it is punishable by death or reclusion perpetua under the law at the time of its commission. Therefore, the RTC correctly exercised its discretion in denying the motion to fix bail, as bail is discretionary, not a matter of right, for capital offenses.