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23.
People vs Valdez
Estrella Sayson was at the canteen preparing for the celebration of the birthday of her second husband. Es-
trella’s son, the deceased Moises Sayson, a former policeman owned the said canteen and managed a betting
station. Estrella’s other sons Joselito and Ferdinand Sayson arrived at the canteen to greet their stepfather.
The celebration was interrupted with the arrival of Eduardo and Edwin. Eduardo and Edwin asked the jai alai
teller, Jonathan Rubio, to come out. Moises approached Eduardo and Edwin and tried to reason with them. Es-
trella saw Eduardo and Edwin armed with guns. Moises went out and advised Eduardo and Edwin not to force
Jonathan to go out of the fronton. Successive shots were thereafter heard. Moises fell and was continuously
fired upon even after he was sprawled on the ground. Ferdinand approached the scene to help his brother
Moises. Ferdinand, however was shot on the left temporal portion of his head and fell. Somebody told Joselito
to run away, but he was hit at the back while running. After shooting the Sayson brothers, Eduardo and Edwin
escaped from the scene of the crime.
The RTC convicted the two accused of three counts of murder.
Issue: W/N the Court should pronounce PO2 Valdez guilty of three homicides, instead of three murders, on ac -
count of the informations not sufficiently alleging the attendance of treachery
Ruling: Yes.
For complaint or information to be sufficient, it must state the name of the accused; the designation of the of -
fense given by the statute; the acts or omissions complained of as constituting the offense; the name of the
offended party; the approximate time of the commission of the offense, and the place wherein the offense
was committed. What is controlling is not the title of the complaint, nor the designation of the offense
charged or the particular law allegedly violated, but the description of the crime charged and the particular
facts therein recited. The acts or omissions complained of must be alleged in such form as is sufficient to en -
able a person of common understanding to know what offense is intended to be charged, and enable the
court to pronounce proper judgment. No information for a crime will be sufficient if it does not accurately and
clearly allege the elements of the crime charged.
Every element of the offense must be stated in the information. What facts and circumstances are necessary
to be included therein must be determined by reference to the definitions and essentials of the specified
crimes. The requirement of alleging the elements of a crime in the information is to inform the accused of
the nature of the accusation against him so as to enable him to suitably prepare his defense. The presump-
tion is that the accused has no independent knowledge of the facts that constitute the offense.
A practical consequence of the non-allegation of a detail that aggravates his liability is to prohibit the introduc-
tion or consideration against the accused of evidence that tends to establish that detail.
24. Zapanta vs People
An Information was filed with the RTC charging the petitioner, with the crime of qualified theft, committed as
follows: That sometime in the month of October 2001, in the City of Baguio, Philippine,… accused ANTHONY
V. ZAPANTA, being then the Project Manager of the Porta Vaga Building Construction, a project being under-
taken then by the Construction Firm, ANMAR, Inc. … steal and carry away from the Porta Vaga project site,
wide flange steel beams of different sizes without the knowledge and consent of the owner ANMAR.
The petitioner submits that, while the information charged him for acts committed sometime in the month of
October 2001, he was convicted for acts not covered by the information, i.e., theft in November 2001, thus de-
priving him of his constitutional right to be informed of the nature and cause of the accusation against him.
Issue: W/N the information was sufficient

Ruling: Yes
Section 6, Rule 110 of the Rules of Criminal Procedure provides:

A complaint or information is sufficient if it states the name of the accused; the designation of the offense
given by the statute; the acts or omissions complained of as constituting the offense; the name of the of-
fended party; the approximate date of the commission of the offense; and the place where the offense was
committed. When an offense is committed by more than one person, all of them shall be included in the com-
plaint or information.
As to the sufficiency of the allegation of the date of the commission of the offense, Section 11, Rule 110 of the
Rules of Criminal Procedure adds:
Section 11. Date of commission of the offense. - It is not necessary to state in the complaint or information the
precise date the offense was committed except when it is a material ingredient of the offense. The offense
may be alleged to have been committed on a date as near as possible to the actual date of its commission.
When the date given in the complaint is not of the essence of the offense, it need not be proven as alleged;
thus, the complaint will be sustained if the proof shows that the offense was committed at any date within the
period of the statute of limitations and before the commencement of the action.
In this case, the petitioner had been fully apprised of the charge of qualified theft since the information stated
the approximate date of the commission of the offense through the words "sometime in the month of Octo-
ber, 2001." The petitioner could reasonably deduce the nature of the criminal act with which he was charged
from a reading of the contents of the information, as well as gather by such reading whatever he needed to
know about the charge to enable him to prepare his defense.

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The RTC convicted the two accused of three counts of murder.

Issue: W/N the information was sufficient

Section 6, Rule 110 of the Rules of Criminal Procedure provides:

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