SUFFICIENCY OF COMPLAINT AND INFORMATION (SEC.

6, RULE 110 OF THE

RULES OF CRIMINAL PROCEDURE)

People v. Sandiganbayan (G.R. No. 160619, 9 September 2015) - Anti-Graft and Corrupt
Practices Act
link: https://lawphil.net/judjuris/juri2015/sep2015/gr_160619_2015.html

“The purpose of an Information is to afford an accused his right to be informed of the

nature and cause of the accusation against him. It is in pursuit of this purpose that the
Rules of Court require that the Information allege the ultimate facts constituting the
elements of the crime charged. Details that do not go into the core of the crime need not
be included in the Information, but may be presented during trial. The rule that evidence
must be presented to establish the existence of the elements of a crime to the point of
moral certainty is only for purposes of conviction. It finds no application in the
determination of whether or not an Information is sufficient to warrant the trial of an
accused.

xxx
This Court, in Lazarte v. Sandiganbayan, explained the two important purposes
underlying the rule. First, it enables the accused to suitably prepare his
defense. Second, it allows the accused, if found guilty, to plead his conviction in a
subsequent prosecution for the same offense. Thus, this Court held that the true test in
ascertaining the validity and sufficiency of an Information is "whether the crime is
described in intelligible terms with such particularity as to apprise the accused, with
reasonable certainty, of the offense charged."

People v. Bayabos (G.R. No. 171222, 18 February 2015) – Hazing

link: https://www.chanrobles.com/cralaw/2015februarydecisions.php?id=108

“Section 14, Article III of the Constitution, recognizes the right of the accused to be
informed of the nature and cause of the accusation against them. As a manifestation of
this constitutional right, the Rules of Court requires that the information charging
persons with an offense be “sufficient.” One of the key components of a “sufficient
information” is the statement of the acts or omissions constituting the offense charged,
subject of the complaint. The information must also be crafted in a language ordinary
and concise enough to enable persons of common understanding to know the offense
being charged against them. This approach is intended to allow them to suitably prepare
for their defense, as they are presumed to have no independent knowledge of the facts
constituting the offense they have purportedly committed. The information need not be
in the same kind of language used in the law relied upon.”

Enrile v. Manalastas (G.R. No. 171222, 18 February 2015) – Less Serious Physical
Injuries
link: https://www.chanrobles.com/cralaw/2014octoberdecisions.php?id=852
 “According to Section 6, Rule 110 of the Rules of Court, the complaint or information is
sufficient if it states the names 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
offended party; the approximate date of the commission of the offense; and the place
where the offense was committed. The fundamental test in determining the sufficiency
of the averments in a complaint or information is, therefore, whether the facts alleged
therein, if hypothetically admitted, constitute the elements of the offense.
xxx

By alleging in their motion to quash that both complaints should be dismissed for lack of
one of the essential elements of less serious physical injuries, the petitioners were
averring that the facts charged did not constitute offenses. To meet the test of sufficiency,
therefore, it is necessary to refer to the law defining the offense charged, which, in this
case, is Article 265 of the Revised Penal Code xxx”

Rosaldes v. People (G.R. No. 173988, 08 October 2014) Child Abuse

link: https://lawphil.net/judjuris/juri2014/oct2014/gr_173988_2014.html

“The information explicitly averred the offense of child abusecharged against the
petitioner in the context of the statutory definition of child abuse found in Section 3 (b) of
Republic Act No. 7610, supra, and thus complied with the requirements of Section 6, Rule
110 of the Rules of Court. Moreover, the Court should no longer entertain the petitioner’s
challenge against the sufficiency of the information in form and substance. Her last
chance to pose the challenge was prior to the time she pleaded to the information
through a motion to quash on the ground that the information did not conform
substantially to the prescribed form, or did not charge an offense. She did not do so,
resulting in her waiver of the challenge.”

People v. Feliciano, (G.R. No. 196735, 05 May 2014) - Murder

link: https://www.lawphil.net/judjuris/juri2014/may2014/gr_196735_2014.html

“An information is sufficient when the accused is fully apprised of the charge against
him to enable him to prepare his defense.
xxx
It is enshrined in our Bill of Rights that "[n]o person shall be held to answer for a
criminal offense without due process of law." This includes the right of the accused to
be presumed innocent until proven guilty and "to be informed of the nature and
accusation against him."
xxx
The test of sufficiency of Information is whether it enables a person of common
understanding to know the charge against him, and the court to render judgment
properly. x x x The purpose is to allow the accused to fully prepare for his defense,
precluding surprises during the trial.”
Matrido v. People (G.R. No. 179061, 13 July 2009) – Qualified theft
link:
https://www.chanrobles.com/scdecisions/jurisprudence2009/jul2009/gr_179061_2009.ph
p

“It is settled that it is the allegations in the Information that determine the nature of
the offense, not the technical name given by the public prosecutor in the preamble of
the Information.
xxx
The recital of facts and circumstances in the Information sufficiently constitutes the
crime of qualified theft.”

Guy v. People (G.R. No. 167088, 20 March 2009) – Anti-Graft and Corrupt
Practices Act
link: https://lawphil.net/judjuris/juri2009/mar2009/gr_166794_2009.html#fnt33

“xxx the specific acts of the accused do not have to be described in detail in the
information, as it is enough that the offense be described with sufficient particularity
to make sure the accused fully understand what he is being charged with. The
particularity must be such that a person of ordinary intelligence immediately knows
what the charge is. Moreover, reasonable certainty in the statement of the crime
suffices.”

Flores v. Layosa (G.R. No. 154714, 12 August 2004) – Falsification of public

Document
Link: https://lawphil.net/judjuris/juri2004/aug2004/gr_154714_2004.html

“Every element of which the offense is composed must be alleged in the complaint or
information by making reference to the definition and the essentials of the specific
crimes. This is so in order to fully apprise the accused of the charge against him and
for him to suitably prepare his defense since he is presumed to have no independent
knowledge of the facts that constitute the offense. It is not necessary, however, that the
imputations be in the language of the statute. What is important is that the crime is
described in intelligible and reasonable certainty.

Moreover, reasonable certainty in the statement of the crime suffices. All that is
required is that the charge be set forth with such particularity as will reasonably
indicate the exact offense of which the accused is alleged to have committed and will
enable him to intelligently prepare his defense, and if found guilty, to plead her
conviction in a subsequent prosecution for the same offense [Balitaan v. CFI of
Batangas, 115 SCRA 729].

In other words, if the offense is stated in such a way that a person of ordinary
intelligence may immediately know what is meant, and the court can decide the
matter according to law, the inevitable conclusion is that the information is valid. It is
not necessary to follow the language of the statute in the information. The information
will be sufficient if it describes the crime defined by law.”