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

Case Summary (G.R. No. 241834)

Chronology and Procedural Posture

Alleged criminal acts were charged to have occurred between September 2011 and January 12, 2012. An Information charging Qualified Trafficking in Persons was filed in the Regional Trial Court (RTC) of Calamba, Laguna (Criminal Case No. 19571-12-C). The RTC rendered a decision finding guilt and imposing an indeterminate sentence (May 26, 2015). The Court of Appeals (CA) affirmed with modification and imposed life imprisonment and a P2,000,000.00 fine (Decision dated January 22, 2018). The CA denied reconsideration (Resolution dated August 23, 2018). The petition under review is the subsequent appeal to the Supreme Court challenging the CA ruling.

Charged Offense and Accusatory Allegations

The Information accused petitioner of recruiting three minors (AAA, BBB, CCC) for the purpose of committing robberies, for money, profit and consideration, thereby violating the Anti‑Trafficking law. The accusations included specific factual allegations: petitioner and his son invited the minors to their residence, the minors were recruited to commit robberies, one minor (CCC) attempted to leave and was allegedly assaulted (punched) by petitioner, and petitioner acted as the getaway tricycle driver in subsequent robberies.

Defense and Counter‑Claims

Petitioner and his son testified that the criminal case was retaliatory, asserting that a certain Lt. HoseAa, an alleged robbery victim, filed theft and obstruction of justice complaints against petitioner which had been dismissed; petitioner alleged the trafficking complaint was a form of reprisal.

RTC Findings

The RTC found the testimonies of the three minor victims to be consistent, direct and unequivocal, and thus credible. The RTC concluded that petitioner recruited minors to perform criminal activities (robberies), constituting Qualified Trafficking in Persons because: (1) the victims were minors, and (2) the offense was committed in “large scale” as it involved three or more victims. The RTC imposed an indeterminate sentence (20 years and 1 day to 22 years) and a fine of P2,000,000.00.

CA Findings and Modification

The CA affirmed the RTC’s factual findings regarding petitioner’s involvement and the credibility of the minors’ testimonies, but modified the penalty, sentencing petitioner to life imprisonment and imposing a P2,000,000.00 fine, with interest. The CA relied on provisions of RA 9208 as amended by RA 10364 (specifically concluding liability under Section 4(k)(4) as amended).

Issue Presented to the Supreme Court

Whether the CA correctly upheld petitioner’s conviction for Qualified Trafficking in Persons given that the specific provision relied upon by the CA (Section 4(k)(4) as introduced by RA 10364) was enacted and took effect after the dates when the alleged acts occurred.

Jurisdictional and Procedural Note by the Court

Although the CA had imposed life imprisonment (which ordinarily requires a notice of appeal under the Revised Rules on Criminal Procedure), petitioner filed a petition for review on certiorari under Rule 45. The Supreme Court, in the interest of substantial justice, treated the filing as an ordinary appeal to address the substantive issues. The Court reiterated that on appeal in criminal cases the entire case is open for review and the appellate tribunal may correct errors, even if unassigned, and may cite the proper penal provision.

Statutory and Legal Framework

Section 3(a) of RA 9208 defines “Trafficking in Persons” broadly to include recruitment, transportation, transfer, harboring, or receipt of persons for purposes of exploitation; it further provides that recruitment of a child for exploitation constitutes trafficking even without the means enumerated for adult victims. Sections 4, 4‑A, 4‑B, 4‑C, and 5 enumerate the specific acts punishable as trafficking; Section 6 identifies circumstances that qualify the offense (e.g., when the trafficked person is a child; when committed by a syndicate or in large scale). Section 10 prescribes penalties, including life imprisonment and fines for Qualified Trafficking.

Statutory Interpretation and Retroactivity Concern

Petitioner argued that he could not be convicted under Section 4(k)(4) of RA 9208 as amended by RA 10364 because that provision was enacted and took effect after the alleged conduct; applying the new provision would be retroactive and contrary to constitutional prohibitions on ex post facto laws. The Court accepted that a newly enacted penal provision cannot be applied retroactively. However, the Court examined whether the acts charged nonetheless fell within existing penal provisions at the time of commission.

Application of Pre‑existing Provision (Section 4(a))

The Court concluded that although conviction under the specific amended provision (Section 4(k)(4)) was not permissible for acts occurring before its effectivity, petitioner’s conduct was nonetheless punishable under the original Section 4(a) of RA 9208 (pre‑amendment). Section 4(a) criminalizes recruiting, transporting, transferring, harboring, providing, or receiving a person by any means for the purpose of prostitution, pornography, sexual exploitation, forced labor, slavery, involuntary servitude or debt bondage. Section 3(d) (original) defines “forced labor and slavery” to include extraction of work or services by enticement, violence, intimidation, use of force/coercion, deprivation of freedom, abuse of authority or deception.

The Court found that petitioner’s acts—recruiting minors to commit robberies—constituted recruitment for the purpose of forced labor or similar exploitation as defined in Section 4(a) and Section 3(d): (a) recruitment was effected through petitioner (via his minor son) of three minors; (b) the means included taking advantage of their vulnerability as minors and the use of violence/coercion (the assault on CCC); and (c) the purpose was to engage the minors in illicit work/services (series of robberies). The Information had sufficiently alleged the ultimate facts constitutive of these circumstances.

Evidentiar

Case Syllabus (G.R. No. 241834)

Procedural History

Petition for review on certiorari (G.R. No. 241834) filed challenging the Court of Appeals (CA) Decision dated January 22, 2018 and Resolution dated August 23, 2018 in CA-G.R. CR No. 37921.
Case originated from an Information filed before the Regional Trial Court (RTC) of the City of Calamba, Laguna, Branch 35, in Criminal Case No. 19571-12-C.
RTC rendered a Decision dated May 26, 2015 finding petitioner guilty beyond reasonable doubt of Qualified Trafficking in Persons and sentenced him to suffer imprisonment for an indeterminate period of twenty (20) years and one (1) day, as minimum, to twenty-two (22) years, as maximum, and imposed a fine of P2,000,000.00.
Petitioner appealed to the CA. In a Decision dated January 22, 2018, the CA affirmed with modification the RTC ruling, finding petitioner guilty of Qualified Trafficking in Persons under Section 4(k)(4) of RA 9208 as amended, and sentenced him to life imprisonment and a fine of P2,000,000.00, with six percent (6%) interest per annum from finality.
Petitioner moved for reconsideration before the CA; the motion was denied in a Resolution dated August 23, 2018.
Petitioner elevated the matter to the Supreme Court by petition for review on certiorari; the Supreme Court noted the improper mode of appeal (given the CA imposed life imprisonment) but, in the interest of substantial justice, treated the petition as an ordinary appeal to resolve the substantive issue.

Facts

The Information alleged that in or about September 2011 up to January 12, 2012 in the City of Calamba, Laguna, petitioner, for money, profit and consideration, willfully, unlawfully and feloniously recruited three minors AAA (13 years old), BBB (16 years old), and CCC (14 years old) for the purpose of committing robbery.
The prosecution alleged that petitioner and his minor son, Dominique Dimple Arambulo (Dominique), invited AAA, BBB, and CCC to their house sometime in 2011 to discuss plans to commit robberies with their assistance.
CCC expressed desire to leave the meeting; petitioner allegedly became angry and punched CCC, compelling him to remain and join the group.
AAA, BBB, and CCC testified that petitioner was the mastermind of a series of robberies they later committed and that petitioner served as the driver of their getaway tricycle.
Petitioner and Dominique testified on their own behalf, asserting that the filing of the case was retaliatory conduct by one Lt. HoseAa (an alleged victim), arising from the dismissal of theft and obstruction of justice cases filed by that alleged victim against petitioner.
The identities of the minor victims were withheld in the record pursuant to Section 7 of RA 9208, as amended.

The Charge (Information)

The accusatory portion of the Information, as quoted in the record, stated: That in or about September 2011 up to January 12, 2012 in the City of Calamba, Province of Laguna and within the jurisdiction of the Honorable Court, the above-named accused for money, profit and consideration, did then and there willfully, unlawfully and feloniously recruit minors AAA, 13 years old, BBB, 16 years old, CCC, 14 years old, for the purpose of committing robbery, to the damage and prejudice of the aforesaid minors and in violation of the aforementioned law. CONTRARY TO LAW.

Trial Court (RTC) Findings and Rationale

The RTC found petitioner guilty beyond reasonable doubt of Qualified Trafficking in Persons.
The RTC relied on the consistent, direct, and unequivocal testimonies of AAA, BBB, and CCC to establish that petitioner recruited them to perform criminal activities (i.e., various robberies).
The RTC concluded that the acts constituted Qualified Trafficking in Persons because: (a) the victims were minors; and (b) the offense was committed "in large scale" as it involved three (3) or more victims.
Based on its findings, the RTC imposed the indeterminate penalty of 20 years and one day to 22 years and a fine of P2,000,000.00.

Appellant’s (Petitioner’s) Principal Contentions on Appeal

Petitioner argued that the act imputed to him — recruiting minors to commit robberies — was charged under Section 4(k)(4) of RA 9208 as amended by RA 10364.
He contended that Section 4(k)(4) was enacted only by RA 10364 which took effect on February 28, 2013, while the alleged acts occurred between September 2011 and January 12, 2012; thus the specific provision relied upon by the CA did not exist at the time the acts were committed.
Petitioner asserted that, because the specific provision was prospective and not retroactive, he could not be convicted under the amended provision and his conviction should be set aside.

Court of Appeals (CA) Ruling

The CA, in its Decision dated January 22, 2018, affirmed the factual findings of the RTC and found petitioner guilty beyond reasonable doubt of Qualified Trafficking in Persons under Section 4(k)(4) of RA 9208, in relation to Section 6(a) and (c), as amended.
The CA imposed the penalty of life imprisonment and a fine of P2,000,000.00, with six percent (6%) per annum interest from finality until fully paid.
The CA held that the prosecution established the commission of the crime and that petitioner was properly informed of the nature and cause of the accusation against him.
Petitioner’s motion for reconsideration before the CA was denied in a Resolution dated August 23, 2018.

Issue Presented to the Supreme Court

Whether the Court of Appeals correctly upheld petitioner’s conviction for Qualified Trafficking in Persons.

Supreme Court’s Preliminary Procedural Observations

The Supreme Court noted that under the Revised Rules on Criminal Procedure, an appeal from a CA decision imposing life imprisonment should be by notice of appeal to the Supreme Court, not by petition for review on certiorari; petitioner nonetheless filed a petition for review on certiorari (Rule 45).
In the interest of substantial justice, the Court treated the petition as an ordinary appeal to resolve the substantive issue.
The Cou