The petitioner was charged with four separate cases of illegal recruitment in 1989 but evaded arrest for over a decade. In 1999, she was arrested and the prosecutor filed a motion to amend the four informations into one information for illegal recruitment in large scale. The trial court denied this motion. The Supreme Court ruled that the rules should be liberally construed and multiple informations can be amended into a single information, as was done in a previous case. The petitioner's argument that this amendment violated her right to bail was misplaced.
The petitioner was charged with four separate cases of illegal recruitment in 1989 but evaded arrest for over a decade. In 1999, she was arrested and the prosecutor filed a motion to amend the four informations into one information for illegal recruitment in large scale. The trial court denied this motion. The Supreme Court ruled that the rules should be liberally construed and multiple informations can be amended into a single information, as was done in a previous case. The petitioner's argument that this amendment violated her right to bail was misplaced.
The petitioner was charged with four separate cases of illegal recruitment in 1989 but evaded arrest for over a decade. In 1999, she was arrested and the prosecutor filed a motion to amend the four informations into one information for illegal recruitment in large scale. The trial court denied this motion. The Supreme Court ruled that the rules should be liberally construed and multiple informations can be amended into a single information, as was done in a previous case. The petitioner's argument that this amendment violated her right to bail was misplaced.
The petitioner was charged with four separate cases of illegal recruitment in 1989 but evaded arrest for over a decade. In 1999, she was arrested and the prosecutor filed a motion to amend the four informations into one information for illegal recruitment in large scale. The trial court denied this motion. The Supreme Court ruled that the rules should be liberally construed and multiple informations can be amended into a single information, as was done in a previous case. The petitioner's argument that this amendment violated her right to bail was misplaced.
Sometime in 1989, the Provincial Prosecutor of Abra filed with the
Regional Trial Court, Branch 1, Bangued, same province, four separate Information for illegal recruitment against Susan Fronda-Baggao, petitioner, and Lawrence Lee, docketed as Criminal Cases Nos. 744, 745, 746 and 749.
Petitioner eluded arrest for more than a decade; hence, the cases against her were archived. On July 25, 1999, petitioner was finally arrested.
On July 26, 1999, the prosecutor filed with the trial court a motion to amend the Information. He prayed that the four separate Informations for illegal recruitment be amended so that there would only be one Information for illegal recruitment in large scale. On the same day, the trial court denied the motion for lack of merit.
Issue:
Whether or not there should be liberal construction of the rules such
that the use of the singular word complaint or information, does not mean that two or more complaints or Information cannot be amended into only one Information.
Held:
Petitioner contends that the amendment of the four Information for
illegal recruitment into a single Information for illegal recruitment in large scale violates her substantial rights as this would deprive her of the right to bail which she already availed of. Such contention is misplaced. We disagree.
A careful scrutiny of the above Rule shows that although it uses the singular word complaint or information, it does not mean that two or more complaints or Information cannot be amended into only one Information. Surely, such could not have been intended by this Court. Otherwise, there can be an absurd situation whereby two or more complaints or Information could no longer be amended into one or more Information. On this point, Section 6, Rule 1 of the Revised Rules of Court is relevant, thus:
SEC. 6. Construction. - These Rules shall be liberally construed in order to
promote their objective of securing a just, speedy and inexpensive disposition of every action and proceeding.
In fact, in Galvez v. Court of Appeals, before the accused were
arraigned, this Court allowed the amendment of three original Information for homicide and frustrated homicide into four Information for murder, frustrated murder and illegal possession of firearms.
Petitioner contends that the amendment of the four Information for
illegal recruitment into a single Information for illegal recruitment in large scale violates her substantial rights as this would deprive her of the right to bail which she already availed of. Such contention is misplaced.
