Arraignment and Plea G.R. No. 164015 February 26, 2009 RAMON A. ALBERT, Petitioner, vs.

THE SANDIGANBAYAN, and THE PEOPLE OF THE PHILIPPINES, Respondents. The practice of the Sandiganbayan of conducting "provisional" or "conditional" arraignments is not sanctioned by the Revised Internal Rules of the Sandiganbayan or by the regular Rules of Court.13 However, in People v. Espinosa,14 this Court tangentially recognized such practice, provided that the alleged conditions attached thereto should be "unmistakable, express, informed and enlightened." Moreover, the conditions must be expressly stated in the Order disposing of the arraignment; otherwise, the arraignment should be deemed simple and unconditional.15

[G.R. No. 135438-39. April 5, 2000] PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. BONIFACIO DURANGO y CARCEDO, accused-appellant.
People vs. Estomaca,[12] which has ruled that no valid judgment can be rendered upon an invalid arraignment, there is here no showing that appellant or his counsel de oficio has been furnished with a copy of each complaint with the list of witnesses against him.

PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ARNEL ALCALDE y PASCASIO, accused-appellant.

SEC. 11. Suspension of arraignment. -- Upon motion by the proper party, the arraignment shall be suspended in the following cases: (a) The accused appears to be suffering from an unsound mental condition which effectively renders him unable to fully understand the charge against him and to plead intelligently thereto. In such case, the court shall order his mental examination and, if necessary, his confinement for such purpose. [Emphasis supplied]. This new requirement of motion by the proper party could not be applied to these cases because the Revised Rules of Criminal Procedure, which prescribes such requirement, took effect only on 1 December 2000. Besides, a waiver must be knowingly and intelligently made by the person possessing such right.[26] Unfortunately, ARNEL was apparently deprived of such mental faculties. Thus, no waiver, impliedly or expressly, could have been made by ARNEL at the time of his arraignment by reason of his mental condition.[27]

Quashal G.R. Nos. 119660-61 February 13, 2009 PAT. EDGARDO HERRERA y BALTORIBIO and PAT. REDENTOR MARIANO y ANTONIO, Petitioners, vs. HONORABLE SANDIGANBAYAN and PEOPLE OF THE PHILIPPINES, Respondents. it was well-within the power of public respondent Sandiganbayan to order the amendment of the information under Section 4, Rule 117 of the Rules on Criminal Procedure which states that if the motion to quash is based on an alleged defect of the complaint or information which can be cured by amendment, the court shall order that an amendment be made. If it is based on the ground that the facts charged do not constitute an offense, the prosecution shall be given by the court an opportunity to correct the defect by amendment. The motion shall be granted if the prosecution fails to make the amendment, or the complaint or information still suffers from the same defect despite the amendment.

G.R. No. 152644 February 10, 2006 JOHN ERIC LONEY, STEVEN PAUL REID and PEDRO B. HERNANDEZ, Petitioners, vs. PEOPLE OF THE PHILIPPINES, Respondent.

Under Section 3(e), Rule 11722 of the 1985 Rules of Criminal Procedure, duplicity of offenses in a single information is a ground to quash the Information. The Rules prohibit the filing of such Information to avoid confusing the accused in preparing his defense.23 Here, however, the prosecution charged each petitioner with four offenses, with each Information charging only one offense. Thus, petitioners erroneously invoke duplicity of charges as a ground to quash the Informations. On this score alone, the petition deserves outright denial.