Fronda-Baggao v. People
CA: In favor of defendants herein
G.R. No. 151785 | 539 SCRA 531 | December 10, 2007 | SANDOVAL-
GUTIERREZ, J
Petition: Petition for Review on Certiorari
Petitioners: Susan Fronda-Baggao
Respondents: People of the Philippines
Amendment of Information
DOCTRINE
 Rules of Procedure allows for an amendment of multiple information into
a singular, graver one.
Relevant Provision
Section 14. Rule 110 of the Revised Rules on Criminal Procedure:
Amendment or substitution. – A complaint or information may be amended,
in form or in substance, without leave of court, at any time before the
accused enters his plea. After the plea and during the trial, a formal
amendment may only be made with leave of court and when it can be done
without causing prejudice to the rights of the accused.
FACTS
a. Petitioner – Wanted for illegal recruitment
b. Respondent –
2. Facts
a. In 1989, the Provincial Prosecutor of Abra filed with RTC Branch
1 of Bangued, four separate Informations for illegal recruitment
against Susan Fronda-Baggao and Lawrence Lee
b. Arrested only on July of 1999, after a decade
c. Prosecutor prayed that the 4 informations be amended so that it
would only be one Information for illegal recruitment in large
scale
d. RTC first denied but subsequently granted upon MR
e. Since it involved economic sabotage, it was forwarded to Branch
2, a Special Criminal Court, which affirmed Branch 1’s decision
f. CA also ruled for the defendants herein
3. Cause of Controversy
a. Petitioner contends that Section 14, Rule 110 of the Revised
Rules on Criminal Procedure refers only to an amendment of
one Information, and not about compounding many information
into a single information; and that
b. the amendment of the four Informations for illegal recruitment
into a single Information for a graver offense violates her
substantial rights.
4. Court Proceedings / Procedural History
a. RTC: Ruled in favor of defendant herein upon MR
b.
ISSUES
1. W/N multiple information can be amended into a singular one
2. W/N such amendment violates the substantial right of the accused
RULING & RATIO
1. YES, it can be amended accordingly
a. Although indeed the Rule uses the singular
word complaint or information, it does not mean that two or more
complaints or Informations cannot be amended into only one
Information
b. Surely not the intention of the Court. Will create an absurd
situation where multiple information cannot be amended into a
singular one
c. The Rules shall be liberally construed in order to promote their
objective of securing a just, speedy and inexpensive disposition
of every action and proceeding
2. NO, it does not violate her substantial rights
a. anchors her contention on the fact that “after the plea and during
the trial, a formal amendment may only be made with leave of
court and when it can be done without causing prejudice to the
rights of the accused”
b. Under the Rules of Court, before the accused enters his plea, a
formal or substantial amendment of the complaint or information
may be made without leave of court. After the entry of a plea,
only a formal amendment may be made but with leave of court
c. After arraignment, a substantial amendment is proscribed except
if the same is beneficial to the accused
d. In this case, petitioner has not yet been arraigned
DISPOSITION
 WHEREFORE, we DENY the petition. The challenged Decision and
Resolution of the Court of Appeals in CA-G.R. SP No. 58270
are AFFIRMED. Costs against petitioner.
Page 1 of 1