Title
Raya vs. People
Case
G.R. No. 237798
Decision Date
May 5, 2021
Accused acquitted of qualified trafficking; CA reversal deemed unconstitutional due to double jeopardy, upholding RTC's demurrer grant despite evidentiary errors.

Case Summary (G.R. No. 237798)

Factual Allegations and Evidentiary Narrative

The Amended Information alleged that petitioners, conspiring and mutually aiding one another, recruited, obtained, hired, provided, offered and transported three complainants (AAA, BBB, CCC) by taking advantage of their vulnerability due to poverty so they could be engaged by another in sexual intercourse or lascivious conduct in exchange for money; the offense was qualified as “large scale” because three complainants were involved. The prosecution presented CCC and several police officers. CCC testified she was a breadwinner introduced to prostitution by a friend (Rose), that Borromeo (“Kate”) and Raya (“Kevin”) pandered her four times a week to one to three customers per night at P1,200 per customer (she received P800; pimps received P400), that on March 26, 2014 the respondents sought five women, and that during a transaction she was pointed out to a customer and police intervened. Police witnesses described a prior surveillance (March 24, 2014) and a coordinated entrapment/rescue operation (March 26, 2014) involving PNP ATCU‑CIDG, DSWD and IJM; SPO2 Bertillo acted as a poseur‑customer, gave two P1,000 bust bills as down payment, the prearranged signal was removal of a cap, Borromeo was arrested and the marked money allegedly recovered from her, Raya was arrested, the victims were secured by DSWD/IJM and taken to Camp Crame where statements were taken and suspects were booked.

Procedural Posture Through the RTC Resolution

Petitioners were arraigned and pleaded not guilty. After the prosecution rested, petitioners filed a demurrer to evidence (June 5, 2015). The trial court (RTC, Branch 263, Marikina City) granted the demurrer by Resolution dated October 5, 2015, effectively acquitting petitioners. The RTC grounded its decision on perceived “discrepancies, inconsistencies and irregularities” in the police officers’ performance and testimonies (e.g., use of a confidential informant despite prior surveillance; contradictions regarding who participated in surveillance; uncertainty about geographic knowledge; late coordination with Cainta police; differing accounts of recovery of marked money), and on the allegation that CCC did not explicitly testify to having been “recruited, obtained, hired, provided, offered and transported” by petitioners as charged.

Court of Appeals Ruling and Rationale

The People filed a petition for certiorari before the Court of Appeals (CA) challenging the RTC’s grant of the demurrer. The CA reversed the RTC in a Decision dated October 19, 2017 and ordered the case reinstated. The CA concluded the RTC placed undue emphasis on collateral and inconsequential inconsistencies (largely concerning the surveillance and internal police procedures) that did not affect the elements of the offense. The CA found that CCC’s testimony sufficiently established that petitioners pimped her—she admitted being pandered by “Kate” and “Kevin,” described frequency, the revenue split, the location of solicitation along Marcos Highway, and the immediate events of March 26, 2014—such that the prosecution had established a prima facie case and the demurrer should not have been granted. A motion for reconsideration by petitioners before the CA was denied on February 22, 2018.

Issue Before the Supreme Court

The central legal question before the Supreme Court was whether the Court of Appeals erred in reversing the RTC’s acquittal (i.e., whether the CA properly entertained and granted the People’s petition for certiorari and effectively allowed further prosecution after an acquittal by demurrer).

Supreme Court: Agreement with RTC Error but Limitation on CA Relief

The Supreme Court agreed with the CA to the extent that the RTC erred in granting the demurrer: many of the RTC’s stated bases for acquittal related to collateral matters immaterial to the elements of qualified trafficking (police tactics, rehearsal of surveillance details, coordination with other police stations, listing of serial numbers of marked money), and CCC’s testimony, when read in full, did in fact support the prosecution’s factual assertions regarding panderage. The RTC had focused on isolated inconsistencies rather than the totality of evidence.

Supreme Court: Certiorari, Finality of Acquittal, and Double Jeopardy Bar

Notwithstanding the foregoing, the Supreme Court held that the CA erred in granting the People’s petition for certiorari to reverse the RTC’s acquittal. The Court explained that certiorari is limited to correcting jurisdictional abuses, not errors of judgment or evaluation of evidence. The 1987 Constitution’s guarantee against double jeopardy (Art. III, Sec. 21) and the finality‑of‑acquittal doctrine bar appellate review that reopens a case after an acquittal resulting from a grant of a demurrer to evidence. The Court reiterated longstanding requisites for attachment of double jeopardy (valid indictment/information, court of competent jurisdiction, arraignment, valid plea, and acquittal/conviction or termination without consent) and emphasized the policy underpinning finality of acquittal: protection of the accused from repeated prosecutions and the State’s one full opportunity to prove guilt.

Exceptions to Finality and Their Non‑application Here

The Court discussed recognized exceptions where a purported acquittal may be revisited: cases where the entire trial was a sham or where the prosecution was denied a fair opportunity to be heard—instances amounting to denial of due process (e.g., Galman, Uy). These are narrow exceptions reserved for situations where the judgment terminating the first jeopardy is void for want of jurisdiction or where the trial was essentially a mockery—suppression of evidence, harassment of witnesses, executive interference, or comparable denial of prosecution’s due process.

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