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

FACTS

Petitioner Felix Nathaniel “Angel” Villanueva Manalo II (Manalo) filed a Motion to Quash the Amended Information on the ground of double jeopardy. The trial court inadvertently read the original Information to Manalo, to which he pleaded not guilty. When the prosecution pointed out the error, the trial court directed the reading of the amended Information. Manalo refused to enter a plea, and the trial court entered a “not guilty” plea on his behalf. Manalo argues that the prosecution is bound by his initial plea to the original Information, and his conviction should only be based on that original charge.

ISSUE

Whether the trial court’s act of reading the amended Information and entering a plea of “not guilty” on Manalo’s behalf, after he had already pleaded not guilty to the original Information, violated his constitutional right against double jeopardy.

RULING

The dissenting opinion argues that Manalo’s right against double jeopardy was violated. The constitutional proscription under Article III, Section 21 of the 1987 Constitution protects an accused from being prosecuted twice for the same offense. The requisites of double jeopardy are present: (1) a first jeopardy attached when Manalo was validly indicted under the original Information before a competent court, arraigned, and entered a valid plea of not guilty; (2) the first jeopardy was terminated without his express consent when the trial court effectively dismissed the original charge by proceeding with the amended Information; and (3) the second jeopardy is for the same offense. The trial court’s mistake in reading the original Information should not prejudice Manalo. His consent to the termination of the case based on the original Information cannot be assumed; it must be express. Therefore, the trial court violated his right by proceeding with the amended Information. The dissenting opinion votes to GRANT the petition.