Information must correctly reflect charges against Accused

Part of the constitutional rights guaranteed to an accused in a criminal case is to be informed of the nature and cause of the charge against him. Correlatively, the State has the obligation to sufficiently allege the circumstances constituting the elements of the crime. Thus, the Information must correctly reflect the charge against the accused before any conviction may be made.[1]

In People v. Solar,[2] the Supreme Court made a pronouncement that in a criminal Information, the State must specify in detail the crime and any circumstance that may qualify the crime or aggravate an accused's liability. Hence, it is no longer sufficient to merely allege the qualifying circumstances of "treachery" or "evident premeditation" without including supporting factual averments. The prosecution must now include in the Information the specific acts and circumstances constituting the attendant circumstances in the crime committed.

[1] See Reyes v. People, G.R. No. 232678, 03 July 2019 [Per CJ Peralta].

[2] G.R. No. 225595, 06 August 2019 [Per J. Caguioa].