### Facts:
Jose Antonio C. Leviste was charged with homicide for the death of Rafael de las Alas on January 12, 2007. The case was raffled to the Regional Trial Court (RTC) of Makati City, Branch 150, presided by Judge Elmo Alameda. Following his arrest and subsequent posting of a P40,000 cash bond, Leviste was released and his arraignment scheduled. The heirs of De las Alas, with the public prosecutor’s conformity, moved for a reinvestigation to determine the correct offense. In response, the RTC issued orders allowing the reinvestigation and admission of the Amended Information for murder, leading to Leviste’s arraignment under the plea of “not guilty.” Leviste’s petitions to the Court of Appeals to challenge the RTC’s orders were denied, prompting his appeal to the Supreme Court.
### Issues:
1. Whether the private complainant had the right to seek reinvestigation after the criminal information was filed.
2. Whether the Judge committed grave abuse of discretion in admitting the Amended Information for murder and issuing warrants of arrest.
3. The validity of Leviste’s participation in the trial against the issues raised regarding the reinvestigation and amended information.
### Court’s Decision:
The Supreme Court found no reversible error by the appellate court, affirming the RTC’s orders that allowed a reinvestigation and admitted the Amended Information for murder. It held that both the prosecution and private complainant could move for reinvestigation before arraignment, subject to the court’s discretion. The Court recognized the discretionary power of prosecutors to determine the charges and noted that modifications before plea entry were permissible, contingent on a new or second preliminary investigation for substantial amendments. The petition was ultimately deemed moot due to the conviction of Leviste for homicide under the Amended Information for murder, but the Court addressed the legal issues to guide future cases.
### Doctrine:
1. A private complainant, with the prosecutor’s conformity, can move for reinvestigation before the arraignment of the accused.
2. An information can be amended, even substantially, before the accused enters a plea, provided a second preliminary investigation is conducted for such substantial amendments.
3. The discretion of whether to allow a reinvestigation and amend the information rests with the court, which must independently evaluate the merits of the case.
### Class Notes:
– **Criminal Procedure**: The process involving the reinvestigation by the prosecution with the court’s approval, highlighting the discretionary powers of the public prosecutor and the trial court’s discretion in accepting a proposed amendment to the information.
– **Right to Preliminary Investigation**: The accused’s entitlement to a second preliminary investigation in cases of substantial amendment of the information before the plea.
– **Doctrine of Mootness**: A case becomes moot and academic if it ceases to present a justiciable controversy due to supervening events, rendering a court’s decision of no practical use or value.
### Historical Background:
This case presents the procedural intricacies in criminal litigation, especially concerning reinvestigation and information amendment processes. It demonstrates the balance between the prosecutorial discretion to charge individuals and judicial oversight to ensure the accused’s rights are protected.
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