FRONDA-BAGGAO v PEOPLE plea, only a formal amendment may be made but with the leave

of court and if it is not prejudicial to the accused’s rights. After

FACTS:
The PP of Abra filed four separate Informations for illegal
recruitment with the RTC. Although the petitioner was elusive
for more than ten years and that the cases against her were
archived, she was still arrested on July 25h, 1999.
arraignment, a substantial amendment is proscribed except if
it’s beneficial to the accused.
Since the petitioner hasn’t entered her plea yet, the four
Informations could still be amended.

The prosecutor filed with the trial court a motion to amend the
Informations, in order to lump the four separate Informations
into one Information for illegal recruitment in large scale. The
trial court denied, to which the prosecutor filed a motion for
reconsideration which the trial court finally granted and
amended the Information.
The petitioner also filed an MR but was denied, so they filed for
certiorari with the CA, which the CA denied.
The petitioner argues that Section 14, Rule 110 of the Revised
Rules on Criminal Procedure refers to an amendment of only one
Information, and not four, which cannot be joined into one. She
adds that to do so would violate her substantial rights.
Anent the petitioner’s contention that Section 14, Rule 110
refers to an amendment of only one Information and not four or
multiple Informations, which cannot be joined into only one, the
Court disagrees.
Section 14, Rule 110 states that although it uses the singular
word “complaint” or “information,” it does not mean that tow
more complaints or Informations cannot be amended into only
one Information. This could surely not have been intended by
the Court, for if it were otherwise, there can be an absurd
situation whereby two or more complaints or Informations could
no longer be amended into one or more Informations.

It must be noted that petitioner has not entered her plea yet.

ISSUE:
Whether or not the four Informations for illegal recruitment be
amended and lumped into one Information for illegal
recruitment in large scale? NO??

RULING:
Before the accused enters his plea, a formal or substantial
amendment may be made without leave of court. After entry of