Sedano v. People
REITERATIONFacts
The Antecedents: Petitioner Marian Rebutay Sedano owned and operated the "Apple Bar Disco Pub" and the "Apple Lodge" in Davao del Norte. The National Bureau of Investigation (NBI), alerted by the Inter-Agency Council Against Trafficking (IACAT), conducted surveillance on the establishment due to reports of employing minors as entertainers. During an operation on January 24, 2014, NBI agents, posing as customers, identified and rounded up several GROs, including minors. Petitioner and her floor manager, Jayflor Delgado, were arrested. Five minors, identified as AAA (15), BBB (16), CCC (17), DDD (17), and EEE (15), subsequently filed complaints against petitioner and Delgado. Procedural History: Petitioner and Delgado were charged with multiple counts of violating the Anti-Trafficking in Persons Act (RA 9208, as amended by RA 10364) and the Special Protection of Children Against Abuse, Exploitation and Discrimination Act (RA 7610, as amended by RA 9231). The Regional Trial Court (RTC) of Davao del Norte, in a Joint Decision dated October 30, 2015, acquitted both petitioner and Delgado, finding that the prosecution failed to prove their guilt beyond reasonable doubt and that the complainants voluntarily applied for the jobs, misrepresenting their ages. The People of the Philippines, through the Office of the Solicitor General (OSG), filed a Petition for Certiorari with the Court of Appeals (CA), alleging grave abuse of discretion by the RTC. The CA granted the petition, reversed the RTC's acquittal, and found petitioner guilty of five counts of violation of Section 4(a), qualified by Section 6(a) of RA 9208, as amended, sentencing her to life imprisonment and a fine for each count. The CA affirmed Delgado's acquittal. The Petition: Petitioner Marian Rebutay Sedano filed a Petition for review on certiorari under Rule 45 of the Rules of Court, assailing the CA's Decision and Resolution. Petitioner argues that the CA's reversal of her acquittal violates her constitutional right against double jeopardy. She contends that the OSG's petition for certiorari was filed out of time, failed to pray for specific reliefs, and that the CA erred in finding grave abuse of discretion on the part of the RTC. Petitioner asserts that the RTC's acquittal was based on a valid appreciation of facts and law, and that the prosecution failed to prove her guilt beyond reasonable doubt. The core issue presented to the Supreme Court is whether the CA's reversal of the acquittal, through a certiorari petition, violated petitioner's right against double jeopardy.
Issue(s)
Whether the Court of Appeals violated the Petitioner's constitutional right against Double Jeopardy by reversing a judgment of acquittal through a Petition for Certiorari. Whether the Regional Trial Court's misapplication of Section 3(a) of Republic Act No. 9208 constitutes grave abuse of discretion or a mere error of judgment. Whether the Office of the Solicitor General's Petition for Certiorari was procedurally infirm for being filed late and lacking a prayer for relief.
Ruling
The petition is GRANTED. The Decision dated 2018-09-26 and the Resolution dated 2019-03-04 of the Court of Appeals in CA-G.R. SP No. 07226 are REVERSED and SET ASIDE. The Regional Trial Court Joint Decision dated 2015-10-30 acquitting the petitioner is REINSTATED. Entry of judgment ordered immediately.
Ratio Decidendi
On Issue 1: The Supreme Court ruled that the Court of Appeals (CA) violated the constitutional prohibition against Double Jeopardy. For double jeopardy to attach, there must be a valid indictment, a competent court, an arraignment, a valid plea, and a termination of the case via acquittal or conviction. All these requisites were met when the Regional Trial Court (RTC) acquitted Petitioner after a full-blown trial. The 'Finality-of-Acquittal' rule is absolute and ensures that an accused, once acquitted, is protected from government oppression through repeated trials. Re-examining the merits of an acquittal, even by an appellate court, places the accused in a constitutionally-offensive second jeopardy. Consequently, the CA had no jurisdiction to reverse the acquittal unless the judgment was void due to a lack of jurisdiction or a total denial of due process. On Issue 2: The Court held that the RTC's error in requiring the element of 'means' (coercion or fraud) for child trafficking was a mere error of judgment, not an error of jurisdiction. Under Section 3(a) of Republic Act No. (RA) 9208, as amended, trafficking of a child is committed regardless of whether coercive or deceptive means are used. However, the RTC's failure to apply this specific provision was a result of its interpretation of the law and appreciation of the evidence presented during the trial. Grave abuse of discretion requires a showing that the court's action was so patent and gross as to amount to an evasion of a positive duty or a virtual refusal to perform a duty. Since the RTC based its decision on its understanding of the evidence—specifically that the minors lied about their ages and volunteered for the work—its ruling was not a 'sham' or 'capricious' exercise of power. Erroneous conclusions of law do not rise to the level of grave abuse of discretion correctible by Certiorari. On Issue 3: The Court noted significant procedural lapses in the Office of the Solicitor General's (OSG) petition that should have barred the CA from entertaining it. First, the petition for certiorari was filed sixty-three (63) days after notice of judgment, which is three days beyond the non-extendible period provided under Rule 65. The OSG's explanation—that it received the endorsement from the Department of Justice late—does not constitute a compelling or exceptional circumstance to warrant a relaxation of the rules. Second, the OSG failed to specify any reliefs in its prayer. It is a basic rule that courts cannot grant relief not prayed for in the pleadings. Because the OSG failed to timely file and specify what it wanted the CA to do (e.g., set aside the acquittal), the RTC's judgment had already attained finality and should not have been disturbed.
Main Doctrine
A judgment of acquittal is final and unappealable; certiorari under Rule 65 is available only to correct grave abuse of discretion amounting to lack or excess of jurisdiction, and may not be used to review errors of judgment which would violate the constitutional prohibition against double jeopardy.