G.R. No. 241834 - Arambulo vs. People

The case stems from an Information filed before the Regional Trial Court (RTC) of Calamba, Laguna, charging Fernando B. Arambulo with the crime of Qualified Trafficking in Persons.

The accusatory portion of the Information alleged that between September 2011 and January 12, 2012, petitioner, for money, profit, and consideration, recruited minors for criminal purposes.

The prosecution asserted that petitioner, along with his minor son Dominique, invited three minor schoolmates (identified as AAA, BBB, and CCC) to their house in 2011.

It was revealed during the meeting that the purpose was to engage in a series of robberies.

When one of the minors (CCC) indicated his wish to leave, petitioner allegedly responded with violence by punching him, thereby coercing his participation.

All three minor witnesses testified that petitioner was the mastermind behind the robberies and even acted as the getaway driver during the criminal activities.

Petitioner, along with his son Dominique, asserted that the case was an act of retaliation by Lt. HoseAa, an alleged victim of the robberies, following the dismissal of previous theft and obstruction of justice charges against him.

The defense maintained that the criminal charges were politically motivated rather than based on the merits of the case.

In the RTC Decision dated May 26, 2015, petitioner was found guilty beyond reasonable doubt and sentenced to imprisonment for an indeterminate period of 20 years and 1 day to 22 years, plus a fine of ₱2,000,000.

The RTC based its conclusion on the consistent, direct, and unequivocal testimonies of the minor witnesses, establishing that petitioner had forcefully recruited minors for committing a series of robberies.

Petitioner appealed the RTC decision to the Court of Appeals (CA), arguing that the crime charged was defined under Section 4(k)(4) of RA 9208, a provision only enacted in 2013, which purportedly could not be applied retroactively to acts committed between September 2011 and January 2012.

The CA, in a decision dated January 22, 2018, affirmed with modification the RTC ruling, convicting petitioner of Qualified Trafficking in Persons under the amended law and sentencing him to life imprisonment along with a fine of ₱2,000,000.

A subsequent motion for reconsideration was denied in a Resolution dated August 23, 2018, prompting the present petition for review on certiorari.

Whether the Court of Appeals correctly upheld petitioner’s conviction for Qualified Trafficking in Persons.
Whether the application of the amended provision (Section 4(k)(4) of RA 9208, as amended by RA 10364) against acts committed prior to its effectivity is valid, given the non-retroactive nature of criminal laws.
Whether the factual findings, particularly the witness testimonies and the circumstances surrounding the recruitment of minors, sufficiently established the elements of Qualified Trafficking in Persons under the original provisions of RA 9208.