G.R. No. 237798 - Raya vs. People

Case Summary (G.R. No. 237798)

Key Dates

Surveillance operations: March 24–26, 2014
RTC acquittal via demurrer: October 5, 2015
CA decision reversing acquittal: October 19, 2017
CA resolution denying reconsideration: February 22, 2018
Supreme Court decision: May 5, 2021

Applicable Law

Republic Act No. 9208, as amended by R.A. 10364 (Anti-Trafficking in Persons Act of 2003, Expanded 2012).
Section 4(e) in relation to Sections 3(a), 3(c) and 6(c): Qualified trafficking.
1987 Constitution, Article III, Section 21: Prohibition against double jeopardy.
Rule on certiorari: review limited to jurisdictional errors.

Factual Background

Raya and Borromeo allegedly conspired to recruit and transport three women (AAA, BBB, CCC) for prostitution along Marcos Highway, Marikina City. CCC, a 27-year-old breadwinner, testified that she and others were introduced to “Kate” (Borromeo) and “Kevin” (Raya) by a friend and were “pimped” at four nights per week, yielding P800 of a P1,200 fee.

Entrapment and Rescue Operation

A joint Philippine National Police–DSWD–IJM team conducted surveillance on March 24, 2014, and an entrapment operation on March 26. SPO2 Bertillo acted as poseur-customer, using marked money. Borromeo negotiated rates inside Jollibee Marikina, accepted P2,000 as down payment, and was arrested after the signal (removal of cap). Raya was apprehended outside the premises; victims were rescued.

Trial Court Proceedings

Petitioners pleaded not guilty. After the prosecution rested, Raya and Borromeo filed a demurrer to evidence. The RTC granted it on October 5, 2015, citing alleged inconsistencies and material discrepancies in police testimonies and CCC’s failure to directly recite statutory trafficking language. The RTC deemed the prosecution’s evidence insufficient for conviction.

Appellate Proceedings

The People filed a petition for certiorari with the Court of Appeals, arguing that the inconsistencies were collateral and did not undermine core elements of qualified trafficking. On October 19, 2017, the CA reversed the acquittal, ordering the case reinstated. A motion for reconsideration was denied on February 22, 2018.

Issue

Whether the Court of Appeals erred in reversing Raya and Borromeo’s acquittal and reinstating criminal proceedings, in light of the prohibition against double jeopardy and the finality-of-acquittal doctrine.

Supreme Court Ruling

RTC Error in Granting Demurrer
– The RTC improperly focused on immaterial law-enforcement details (use of informant, coordination issues, evidence marking) and isolated testimonial inconsistencies. Core elements of recruitment, transport, and exploitation were amply proven by CCC’s testimony and police evidence.
CA’s Jurisdictional Misstep
– Certiorari lies only for jurisdictional defects or grave abuse of discretion amounting to lack or excess of jurisdiction. The CA treated non-jurisdictional errors of factual assessment as jurisdictional, exceeding its authority.
Double Jeopardy and Finality of Acquittal
– Article III, Section 21 of the 1987 Constitution guarantees that no person shall be twice put in jeopardy for the same offense. Jeopardy attached upon arraignment and plea; acquittal on demurrer is a final judgment. The finality-of-acquittal doctrine bars any appeal or retrial absent denial of due process amounting t

Case Syllabus (G.R. No. 237798)

Procedural History

Petitioners Marwin B. Raya and Shiela C. Borromeo were charged by Amended Information with Qualified Trafficking in Persons under R.A. No. 9208, as amended by R.A. No. 10364.
At trial before RTC Branch 263, Marikina City, petitioners pleaded not guilty; after the prosecution rested, petitioners filed a demurrer to evidence.
On October 5, 2015, the RTC granted the demurrer and acquitted petitioners for alleged inconsistencies and irregularities in the prosecution’s evidence.
The People filed a petition for certiorari before the Court of Appeals (CA) alleging grave abuse of discretion; on October 19, 2017, the CA reversed the acquittal and reinstated the charges.
Petitioners’ motion for reconsideration was denied by the CA on February 22, 2018.
Petitioners elevated the case to the Supreme Court via a petition for review on certiorari.

Facts

The Amended Information alleged that prior to and on March 26, 2014, Raya (“Kevin”) and Borromeo (“Kate”) recruited and transported three women—AAA, BBB, and CCC—into a fast-food restaurant on Marcos Highway, Marikina City, to engage in sexual intercourse for money, taking advantage of their poverty.
CCC testified she was introduced to prostitution by her friend Rose and then to the respondents; she was “pimped” four times a week, earning ₱800 of a ₱1,200 fee per customer.
A joint surveillance by the PNP Anti-Transnational Crime Unit-CIDG, DSWD, and IJM was conducted on March 24, 2014, confirming the trafficking pattern along Marcos Highway and nearby areas.
An entrapment/rescue operation on March 26, 2014, was carried out using marked money as bait, a confidential informant, and a pre-arranged signal (removal of cap).
Police officers (SPO2 Bertillo, PO3 Lace, PSSupt. Guyguyon, and SPO3 Castroverde) arrested Borromeo inside Jollibee and Raya outside; the victims were rescued and their statements taken at Camp Crame.

RTC Ruling

The RTC granted petitioners’ demurrer to evidence on October 5, 2015, citing:
•