In People of the Philippines v. Alberto Gonzales Jr., the Supreme Court addressed whether an accused can be convicted of multiple counts of an offense when the information (the formal charge) appears to allege only a single instance. The Court ruled that if the accused is fully aware of and defends against multiple charges throughout the trial, a conviction on those charges can stand, even if there are technical defects in the initial charging documents. This decision clarifies the importance of due process and the rights of the accused to be fully informed of the charges against them, but also prevents defendants from escaping accountability based on mere technicalities where the substance of the accusation is clear.

Alberto Gonzales Jr.’s Predicament: Can an Accused Face Multiple Rape Charges with an Information Alleging Only One?

The case revolves around Alberto Gonzales Jr., who was convicted of two counts of rape by the Regional Trial Court (RTC) of San Mateo, Rizal. On March 4, 1998, Alberto Gonzales Jr. was accused with multiple counts of rape; the Informations presented by the prosecution side bear the same context in each account, however, it also had separate numbers and corresponding details in relation to the numbers. Gonzales appealed this conviction, arguing that the information filed against him alleged only a single offense of rape, making the conviction for two counts invalid. He further contended that inconsistencies in the victim’s testimony and lack of resistance from her side should have led to his acquittal.

The Supreme Court, in reviewing the case, emphasized several critical points. First, the records indicated that four informations were actually filed against Gonzales: two original and two amended. Although identically worded, these informations bore separate case numbers, specifically Criminal Case Nos. 3514 and 3515. The Court highlighted that the amended informations mirrored the originals, except for the change in the victim’s age, which was revised from 15 to 16 years. Second, the Supreme Court also presented as evidence the Orders of the trial court that explicitly acknowledges multiple cases filed against the appellant which sufficiently put him on notice for more than one count of rape; the case records are as follows:

“ORDER

“When these cases were called for arraignment, accused Alberto Gonzales, Jr., after x x x the Informations [were read to him] in a language known to him which [was] Filipino, x x x entered a plea of Not Guilty to the offense charged.

“Accordingly, let a plea of Not Guilty be entered into the records of these cases for accused Alberto Gonzales, Jr. who has been assisted in today’s arraignment by Atty. Regino Garillo.

Moreover, the Supreme Court underscored that he had been arraigned separately for each of the charges. With the documentary evidence and supporting facts on hand, the High Court determined that there was no way Alberto Gonzales was oblivious to the charges against him. He cannot claim that he was unaware that he was facing two counts of rape. Moreover, it was discovered that the filing of the amended version of the information came in response to the presentation of the victim’s Birth Certificate wherein it was shown that the victim’s real age at the time of the offense was sixteen (16) years old. Hence, to adhere to evidence and truth, a Motion with Leave of Court to Amend and Admit Attached Amended Informations was filed by the assistant provincial prosecutor.

Building on this point, the Court noted that the appellant’s counsel raised no objection to the said Motion to Amend before the trial court. The Supreme Court’s review highlighted the fact that the victim had clearly testified on two instances of rape during the trial, during which Gonzales, through his counsel, cross-examined her on both counts. This acknowledgment of the appellant’s clear awareness that he was facing two counts of rape prompted the court to act favorably and accord him ample chance to defend himself against both charges.

The Supreme Court pointed out that after Gonzales had entered his plea during his arraignment, it was already too late for him to assail the validity of the Informations filed against him. The Court, in citing a related case of People v. Gopio, emphasized the proper course of action regarding similar incidents.

“In any event, it is now too late in the day to question the form or substance of the information because when he entered his plea at his arraignment, accused-appellant did not object to the sufficiency of the information against him.  The rule is that, at any time before entering his plea, the accused may move to quash the information on the ground that it does not conform substantially to the prescribed form. 

This is especially true if the defendant did not question any grounds for a motion to quash before he pleads to the information. This failure shall be deemed a waiver of the grounds for a motion to quash, except when the grounds are that no offense was charged, the court trying the case has no jurisdiction over the offense charged, the offense or penalty has been extinguished, and the accused would be twice put in jeopardy.”

FAQs

What was the key issue in this case?	The primary issue was whether Alberto Gonzales Jr. could be convicted of two counts of rape when the information filed against him allegedly charged only one offense. This raised questions about the sufficiency of the information and the defendant’s due process rights.
Why did the Supreme Court uphold the conviction despite the appellant’s claim that the Information was defective?	The Court upheld the conviction because it found that Gonzales was fully aware that he was being charged with two counts of rape. Evidences presented such as court orders that acknowledges multiple charges and cross-examination of the victim related to the separate charges, sufficiently proved awareness of the charges on the appellant’s end.
What were the key factors that demonstrated Alberto Gonzales Jr.’s awareness of the multiple charges?	The court found these several factors such as the multiple informations filed, the arraignment for each count, and the appellant’s cross-examination of the victim on both alleged incidents of rape showed clear awareness of multiple charges. These collective pieces of evidence negated Gonzales’ argument.
What did the Court mean regarding Gonzales’ awareness of the multiple charges?	The trial transcripts sufficiently indicated that during his arraignment and defense posture, Alberto Gonzales Jr. had reasonable comprehension and knowledge that he was facing not just one, but two counts of rape brought before him for legal consideration.
What is the significance of a “Motion to Quash” in a case like this?	A Motion to Quash is a legal move where the accused asks the court to void or dismiss the information due to some defects or lack of conformity. The failure of Gonzales’ lawyers to file such motion serves as an acknowledgement and acceptance of the multiple counts.
Did the Supreme Court address the credibility of the victim’s testimony?	Yes, the Supreme Court affirmed the trial court’s assessment of the victim’s testimony as credible, noting that there was no indication of ill motive on her part to fabricate such serious charges and that material evidences supported the victims statement.
How did the Supreme Court address the inconsistencies Gonzales brought up?	The Supreme Court viewed them as minor and not critical enough to undermine the victim’s overall account. It reasoned that minor discrepancies could arise due to recounting a traumatic event.
Were moral damages and indemnity awarded in this case?	Yes, the Supreme Court affirmed the award of moral damages. Additionally, it modified the decision to grant the victim an indemnity ex delicto of P50,000 for each count of rape.

Ultimately, the Supreme Court’s decision in People v. Alberto Gonzales Jr. underscores the necessity of procedural awareness in legal defense and prosecution. While the information might have been initially defective, the defendant’s acknowledgment and engagement with the multiple charges negated the potential prejudice, thereby preventing the appellant’s possible escape from the punishment. The Supreme Court decision solidifies its firm stand that in every judicial procedure, technical defects will not prevail over the essence of due process, fair trial, and search for justice.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People of the Philippines vs. Alberto Gonzales Jr., G.R. Nos. 143143-44, January 15, 2002