G.R. No. 246306 , July 26, 2023
MARIAN REBUTAY SEDANO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

Petitioner Marian Rebuta y Sedaño (Rebuta) was charged with five counts of violation of the Anti-Trafficking in Persons Act (RA 9208, as amended by RA 10364) and five counts of violation of the Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act (RA 7610, as amended by RA 9231). After trial, the Regional Trial Court (RTC) issued a Joint Decision acquitting Rebuta of all charges. The RTC found that the prosecution failed to prove her guilt beyond reasonable doubt, noting that the private complainants voluntarily applied for jobs as GROs, lied about their ages, and that no threat, force, coercion, abduction, fraud, or deception was employed by Rebuta. The prosecution, through the Office of the Solicitor General, filed a petition for certiorari with the Court of Appeals (CA). The CA granted the petition, reversed the RTC’s Joint Decision, and convicted Rebuta of qualified trafficking, sentencing her to life imprisonment and fines. Rebuta filed a petition before the Supreme Court, alleging that the CA’s reversal violated her constitutional right against double jeopardy.

ISSUE

Whether the Court of Appeals erred in reversing the Regional Trial Court’s judgment of acquittal, thereby violating petitioner’s constitutional right against double jeopardy.

RULING

Yes. The Supreme Court, through the concurring opinion, held that the CA erred in reversing the RTC’s acquittal. All elements of double jeopardy are present: (1) Rebuta was validly indicted before a competent court; (2) she was arraigned and pleaded not guilty; (3) the case was terminated after a full-blown trial where both parties presented evidence; and (4) the RTC issued a judgment of acquittal. The “finality-of-acquittal” rule bars the reversal of an acquittal, as it is final, unappealable, and immediately executory. The CA’s act of granting the petition for certiorari, reversing the acquittal, and convicting Rebuta constituted a second jeopardy for the same offense. The narrow exception to this rule—where the prosecution is denied due process—does not apply, as the prosecution was not denied the opportunity to present its case; the trial was not a sham. Therefore, the CA’s decision violated Rebuta’s right against double jeopardy.