G.R. No. 113213 - Wright vs. Court of Appeals

On March 7, 1988, the Republic of the Philippines and Australia concluded a Treaty of Extradition, ratified by the Philippine Senate on September 10, 1990, and effective thirty days after mutual notification of compliance with entry‐into‐force requirements.
The Treaty adopts a non‐list approach and requires double criminality, covering all offenses punishable by at least one year’s imprisonment; it expressly allows extradition for offenses committed before the Treaty’s effectivity, provided they were offenses in the Requesting State at the time of commission. It further prescribes documentary prerequisites (Article 6) and authentication and certification requirements (Article 7).

Paul Joseph Wright is an Australian citizen, an insurance agent, married to a Filipina with one child, and at the time of arrest was unemployed.
Australia sought his extradition for indictable crimes under the Victorian Crimes Act of 1958:

Wright/Orr matter: one count of Obtaining Property by Deception (Section 81[1]) involving US$315,250 obtained by false representation of duly signed mortgage documents.
Wright/Cracker matter: thirteen counts of Obtaining Property by Deception (Section 81[1]), one count of Attempting to Obtain Property by Deception (Section 321[m]), and one count of Perjury (Section 314), arising from false life‐insurance proposals, sham policy‐holder inducements, and a statutory declaration containing false statements.

On March 17, 1993, DFA transmitted Diplomatic Note No. 080/93 (dated February 19, 1993) with formal extradition request and supporting documents.
On April 6, 1993, DOJ State Counsels filed extradition proceedings before RTC Makati Branch 139; RTC ordered petitioner’s arrest (served April 26, 1993 by NBI) and detention pending trial.
Petitioner filed an answer denying knowledge of any Australian case, asserting multiple entries and stays in the Philippines since 1990, and claimed misplacement of his tourist‐visa documents.

RTC Branch 139, Makati (June 14, 1993): granted Australia’s extradition request, finding that the charges constitute extraditable offenses under Treaty Articles 2, 6, and 7, and that retroactive application is permissible under Article 2(4).
Court of Appeals (September 14, 1993; recon. denied December 16, 1993): affirmed RTC decision, holding that Treaty requirements were met, that “wanted for prosecution” is satisfied by a warrant and statement of acts, and that retroactivity and inference of evasion do not violate constitutional or legal norms.

Does applying the Treaty retroactively to offenses committed before its effectivity constitute an ex post facto law under the Constitution?
Do the submitted documents satisfy the Treaty’s requirements and sufficiently show that petitioner is “wanted for prosecution” in Australia?
Did the trial court abuse its discretion in interpreting petitioner’s extended stay in the Philippines as evidence of an intent to evade prosecution?
Is the extradition order invalid for failing to specify the precise charges on which petitioner is to stand trial?