Case Digest (G.R. No. 241834)
Facts:
Fernando B. Arambullo v. People of the Philippines, G.R. No. 241834, July 24, 2019, the Supreme Court Second Division, Perlas‑Bernabe, J., writing for the Court.Petitioner Fernando B. Arambullo was charged by Information with Qualified Trafficking in Persons for allegedly recruiting three (3) minors — identified in the records as AAA, BBB, and CCC — between September 2011 and January 12, 2012 in Calamba City, Laguna, for the purpose of committing robberies. The Information alleged petitioner, for money or profit, recruited those minors to commit crimes; the minors later testified that petitioner was the mastermind and that he drove the getaway tricycle, and CCC testified he was punched when he tried to leave, evidence the prosecution said showed coercion.
At trial before the Regional Trial Court (RTC), petitioner and his minor son, Dominique, testified the case was retaliatory, alleging a certain police officer filed previous complaints of theft and obstruction of justice against petitioner. The RTC, in a Decision dated May 26, 2015 (Criminal Case No. 19571‑12‑C), found petitioner guilty beyond reasonable doubt of Qualified Trafficking in Persons and sentenced him to an indeterminate term of 20 years and one day to 22 years, plus a P2,000,000 fine.
Petitioner appealed to the Court of Appeals (CA). He argued among other points that the specific provision relied upon by the CA — Section 4(k)(4) of RA 9208, as amended by RA 10364 (effective February 28, 2013) — was enacted after the alleged acts (2011–2012) and therefore could not be the basis of a conviction. In its Decision dated January 22, 2018 (CA‑G.R. CR No. 37921), the CA affirmed with modification, finding petitioner guilty of Qualified Trafficking in Persons under Section 4(k)(4) in relation to Section 6(a) and (c) of RA 9208, as amended, and sentenced him to life imprisonment and a P2,000,000 fine. Petitioner’s motion for reconsideration was denied by CA Resolution dated August 23, 2018.
Petitioner filed a petition for review on certiorari before the Supreme Court. The Court noted petitioner invoked Rule 45 even th...(Subscriber-Only)
Issues:
- Was the petition for review under Rule 45 a proper mode of appeal when the Court of Appeals imposed life imprisonment, and if not, should the Supreme Court nevertheless entertain the petition?
- Did the Court of Appeals correctly affirm petitioner’s conviction for Qualified Trafficking in Persons and correctly identify the statutory provision under which he should be convicted?
- What is the proper penalty and monetary awards...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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