G.R. No. 159252 . March 11, 2005.
PEOPLE OF THE PHILIPPINES, Appellee, vs. ROSARIO “ROSE” OCHOA, Appellant.

FACTS

Appellant Rosario Ochoa was charged before the Regional Trial Court (RTC) of Quezon City with Illegal Recruitment in Large Scale (Criminal Case No. 98-77300) and three counts of Estafa (Criminal Case Nos. 98-77301 to 98-77303). The Information alleged that from February 1997 to April 1998, without a license from the Department of Labor and Employment, she recruited fifteen individuals for overseas employment, collecting fees ranging from ₱2,000 to ₱32,000. The three Estafa cases involved specific complainants to whom she made false promises of employment in Taiwan. After a joint trial, the RTC convicted Ochoa on all counts, sentencing her to life imprisonment and a fine for illegal recruitment and to indeterminate prison terms for each count of estafa.
Ochoa appealed the RTC decision to the Court of Appeals (CA). The CA initially affirmed the conviction in a June 17, 2002 decision. However, upon Ochoa’s motion for reconsideration, the CA nullified its own decision in a Resolution dated August 6, 2003. It held that since the penalty imposed was life imprisonment, it had no jurisdiction over the appeal under the Constitution and the Rules of Court. Citing Limpangog v. Court of Appeals, instead of dismissing the appeal, the CA ordered the transfer of the case records to the Supreme Court.

ISSUE

Whether the Court of Appeals correctly transferred the case to the Supreme Court, given that the appellant was sentenced to life imprisonment for Illegal Recruitment in Large Scale.

RULING

The Supreme Court ordered the return of the case to the Court of Appeals for a decision on the merits. The legal logic is anchored on the Court’s intervening ruling in People v. Efren Mateo (G.R. No. 147678-87, July 7, 2004) and the subsequent amendment of the Rules of Criminal Procedure. In Mateo, the Court established that appeals from RTC judgments imposing reclusion perpetua or life imprisonment should be taken to the CA, not directly to the Supreme Court. This procedure allows for a review by an intermediate appellate court, which can correct any errors and formulate a more complete factual and legal analysis, thereby aiding the Supreme Court’s review process if a further appeal is pursued.
This rule was formally institutionalized through the Court’s resolution in Administrative Matter No. 00-5-03-SC, which revised Section 3(c), Rule 122 of the Revised Rules of Criminal Procedure, effective October 15, 2004. The revised rule explicitly states that an appeal to the Supreme Court in cases where the RTC imposes reclusion perpetua or life imprisonment shall be taken by filing a notice of appeal to the Court of Appeals. Consequently, the CA’s reliance on Limpangog was superseded by this new procedural regime. The Supreme Court thus directed the CA to raffle the case to a regular division and to decide the appeal on its merits.