People v. Ochoa
REITERATIONFacts
The Antecedents: An Information was filed charging appellant Rosario "Rose" Ochoa with illegal recruitment in large scale for recruiting several individuals for employment abroad for a total consideration of ₱124,000.00 without the necessary license from the Department of Labor and Employment. Three other Informations for estafa were filed against her for recruiting individuals for employment in Taiwan, collecting placement fees without fulfilling her promise. The cases were consolidated and jointly tried. Procedural History: The Regional Trial Court (RTC) of Quezon City, Branch 104, convicted appellant Ochoa of illegal recruitment in large scale and three counts of estafa. She was sentenced to life imprisonment for illegal recruitment and indeterminate penalties for estafa, with indemnification to the complainants. Appellant appealed to the Court of Appeals (CA). The CA initially affirmed the RTC decision but later nullified its own decision, citing lack of jurisdiction because the penalty imposed for illegal recruitment was life imprisonment. The CA, however, ordered the transfer of the case to the Supreme Court, citing Limpangog v. Court of Appeals. The Petition: The Supreme Court resolved to return the case to the CA for a decision on the merits, considering its pronouncements in People of the Philippines v. Efren Mateo and the amendment to Rule 122, Section 3(c) of the Revised Rules of Criminal Procedure.
Issue(s)
Whether the Court of Appeals erred in nullifying its decision and ordering the transfer of the case to the Supreme Court. Whether the Supreme Court has jurisdiction over the appeal.
Ruling
The Supreme Court ordered the transfer of the records of the case to the Court of Appeals for a decision on the merits. The appellate court was directed to raffle the case to any of its regular divisions.
Ratio Decidendi
On the issue of the Court of Appeals' error in nullifying its decision: The Court of Appeals erred in nullifying its decision and ordering the transfer of the case to the Supreme Court. Appeals from decisions of the RTC, wherein the accused is sentenced to suffer life imprisonment or reclusion perpetua, should be made to the Court of Appeals, according to the amended Rule 122, Section 3(c) of the Revised Rules of Criminal Procedure, which took effect on October 15, 2004. The CA's initial decision to affirm the RTC ruling was therefore correct in terms of jurisdiction, but its subsequent nullification and transfer to the Supreme Court was erroneous. The CA should have proceeded to decide the appeal on its merits, as it had already acquired jurisdiction over the case when the appeal was filed. The CA's reliance on Limpangog v. Court of Appeals was misplaced given the subsequent amendment to the rules. On the issue of the Supreme Court's jurisdiction: Given the amendment to Rule 122, Section 3(c) of the Revised Rules of Criminal Procedure, the Supreme Court does not have direct appellate jurisdiction over cases where the RTC sentences the accused to life imprisonment or reclusion perpetua. Such appeals should be filed with the Court of Appeals. The Court reiterated its ruling in People of the Philippines v. Efren Mateo in this regard.
Main Doctrine
Appeals from decisions of the Regional Trial Court imposing life imprisonment or reclusion perpetua should be filed with the Court of Appeals, and not directly with the Supreme Court, in accordance with the Revised Rules of Criminal Procedure.