Case Digest (G.R. No. L-24968)
Facts:
In Fernando B. Arambullo v. People of the Philippines (G.R. No. 241834, July 24, 2019), petitioner Fernando B. Arambullo and his minor son, Dominique, were charged before the Regional Trial Court (RTC), Branch 35, Calamba, Laguna, with Qualified Trafficking in Persons under Section 4(k)(4) in relation to Section 6(a) and (c) of Republic Act No. 9208, as amended by RA 10364. The Information alleged that from September 2011 to January 12, 2012, in Calamba, Laguna, Arambullo recruited three schoolmates—AAA (13 years old), BBB (16 years old), and CCC (14 years old)—for the purpose of committing a series of robberies. The minors testified that petitioner forced them—using threats, physical violence and coercion—to join the scheme and even served as their getaway driver on a tricycle. Arambullo and Dominique claimed the accusations were retaliatory, arising from prior dismissed theft and obstruction of justice charges filed by Lt. HoseAa, an alleged robbery victim. The RTC, after findCase Digest (G.R. No. L-24968)
Facts:
- Criminal Charge and Synopsis
- In September 2011 to January 12, 2012, petitioner Fernando B. Arambullo and his minor son Dominique recruited three minors—AAA (13), BBB (16), and CCC (14)—to their Calamba, Laguna residence for the purpose of committing a series of robberies.
- According to AAA, BBB, and CCC:
- They were lured into the plan, and when CCC attempted to leave, petitioner punched him, coercing his continued participation.
- Petitioner acted as mastermind and getaway tricycle driver during the robberies.
- Defense and Procedural History
- Petitioner and Dominique claimed the trafficking charge was retaliatory, filed by one Lt. HoseAa after the dismissal of theft and obstruction cases he filed against petitioner.
- RTC, Branch 35, Calamba City (Decision, May 26, 2015):
- Convicted petitioner of Qualified Trafficking in Persons under RA 9208 (as amended), sentencing him to 20 years and 1 day to 22 years imprisonment and a P2,000,000 fine.
- Found elements established through consistent, direct, and unequivocal testimony; qualified trafficking due to victims being minors and “large scale” (three or more victims).
- Court of Appeals (Decision, Jan. 22, 2018; Resolution, Aug. 23, 2018):
- Affirmed with modification, convicting under Section 4(k)(4) of RA 9208, as amended by RA 10364, sentencing petitioner to life imprisonment and a P2,000,000 fine with 6% annual interest.
- Denied petitioner’s motion for reconsideration on August 23, 2018.
- Supreme Court petition: Petitioner filed a petition for review on certiorari under Rule 45, despite a life sentence—technically the wrong mode of appeal, but accepted for substantive review.
Issues:
- Primary Issue
- Whether the Court of Appeals correctly upheld petitioner’s conviction for Qualified Trafficking in Persons under RA 9208, as amended.
- Subsidiary Considerations
- Whether Section 4(k)(4) of RA 9208, as amended by RA 10364, applies retroactively to acts committed before its effectivity (Feb. 28, 2013).
- Whether petitioner’s acts fall under another provision of RA 9208 in its original form.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)