Case Digest (G.R. No. 246306)
Facts:
Marian Rebuta Sedano v. People of the Philippines, G.R. No. 246306, July 26, 2023, Supreme Court Third Division, Inting, J., writing for the Court.Petitioner Marian Rebuta y Sedano (petitioner) was the registered owner and proprietor of the Apple Bar Disco Pub (two branches) and of a lodge where employees resided; Jayson (Jayflor) Delgado y Gabayan (Delgado) was her floor manager. On January 24, 2014, following an information from the Inter‑Agency Council Against Trafficking (IACAT), National Bureau of Investigation (NBI) agents conducted a raid at one branch of the bar after an undercover check suggested some guest relations officers (GROs) were minors; a social worker and a dentist accompanied the operation and five girls were preliminarily identified as minors (assigned pseudonyms AAA–EEE) and brought for dental examinations and protective custody.
As a result of the operation the five minors filed complaints and petitioner and Delgado were charged in multiple informations: Criminal Case Nos. 19762, 19763, 19764, 19765, 19766, 19767, 19768, 19769, 20112 and 20113 (variously for qualified trafficking under RA 9208 as amended by RA 10364, and violations of RA 7610, as amended by RA 9231). At arraignment both pleaded not guilty and a full trial ensued. The Regional Trial Court (RTC), Branch ___, issued a Joint Decision dated October 30, 2015, acquitting petitioner and Delgado of all charges on the ground that the prosecution failed to prove coercion or other “means” and that the complainants had voluntarily applied for work and had misrepresented their ages; the RTC expressly relied on factual findings and cited People v. Lalli in its discussion.
The Office of the Solicitor General (OSG) for the People filed a petition for certiorari in the Court of Appeals (CA-G.R. SP No. 07226) alleging grave abuse of discretion by the RTC. The CA granted that petition in a Decision dated September 26, 2018, reversed and set aside the RTC acquittal, convicted petitioner of five counts of qualified trafficking (Section 4(a) qualified by Section 6(a), RA 9208 as amended), sentenced her to life imprisonment and P2,000,000.00 fine per count, and awarded moral/exemplary damages; Delgado’s acquittal was affirmed. The CA denied petitioner’s motion for reconsideration in a Resolution dated March 4, 2019.
Petitioner then filed a petition for review on certiorari under Rule 45 before the Supreme Court, assailing the CA decision mainly on double jeopardy grounds and also alleging, inter ali...(Pro-only)
Issues:
- Did the Court of Appeals violate petitioner’s constitutional protection against double jeopardy by reversing the RTC’s acquittal and entering a conviction?
- Was the petition for certiorari filed by the People in the Court of Appeals timely under Rule 65, and if not, did any exceptional circumstance justify extension?
- Did the People’s petition to the CA fail for lack of specification of the reliefs prayed for, thereby violating due process?
- Should the Court decide the validity of the warrantless search and arrest of petitio...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)