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

FACTS

Petitioner Marian Rebutay Sedano is the registered owner and proprietor of the Bar Disco Pub (Bar) and a lodge where its employees reside. Her co-accused, Jayflor Delgado, was the floor manager. In January 2014, the National Bureau of Investigation (NBI), acting on a report from the Inter-Agency Council Against Trafficking (IACAT), conducted a surveillance and subsequent operation on the Bar. The NBI agents, accompanied by a social worker and a dentist, rounded up girls working as entertainers/Guest Relations Officers (GROs). Petitioner and Delgado were arrested. Five girls were identified as minors: AAA (15), BBB (16), CCC (17), DDD (17), and EEE (15). They were taken into custody, underwent dental examination for age determination, and filed complaints.
Petitioner and Delgado were charged with five counts of Qualified Trafficking in Persons under Section 4(a) in relation to Section 6(a) of Republic Act (RA) No. 9208 (Anti-Trafficking in Persons Act of 2003), as expanded by RA 10364, in relation to RA 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination Act). They were also charged with four counts of violation of Section 12-D(4)(b) of RA 7610 (engaging a child in worst forms of labor). The Regional Trial Court (RTC) acquitted both accused of all charges. The People, through the Office of the Solicitor General, filed a Petition for Certiorari before the Court of Appeals (CA) assailing the acquittal. The CA granted the petition, reversed the RTC’s acquittal of petitioner, and found her guilty beyond reasonable doubt of five counts of Qualified Trafficking in Persons, sentencing her to life imprisonment and a fine of P2,000,000.00 for each count, plus damages. The CA affirmed Delgado’s acquittal. Petitioner filed the present Petition for Review on Certiorari.

ISSUE

Whether the Court of Appeals erred in granting the Petition for Certiorari and reversing the trial court’s judgment of acquittal.

RULING

The Supreme Court GRANTED the petition, REVERSED and SET ASIDE the Decision and Resolution of the Court of Appeals, and REINSTATED the Joint Decision of the Regional Trial Court acquitting petitioner Marian Rebutay Sedano of all charges.
The Court held that a judgment of acquittal is final and unappealable. The only exception is when the prosecution is denied due process, such as when the trial court commits grave abuse of discretion amounting to lack or excess of jurisdiction in issuing a judgment of acquittal. In this case, the People failed to prove that the RTC committed grave abuse of discretion. The RTC’s decision was based on its evaluation of the evidence, specifically finding that the prosecution failed to prove the elements of the crimes charged, particularly the act of “hiring, receiving, or harboring” the minors for exploitation. The RTC found that the prosecution’s evidence did not establish that petitioner actively recruited or employed the minors, noting the minors’ testimonies were inconsistent and failed to detail their recruitment or the specific acts of petitioner. The RTC also found the evidence insufficient to prove the alleged sexual acts or that petitioner offered the minors for prostitution. The Supreme Court ruled that the CA erred in re-evaluating the evidence and substituting its own judgment for that of the trial court, which is not permitted in a certiorari proceeding challenging an acquittal. The RTC’s conclusions were based on the evidence and did not constitute a capricious, whimsical, or arbitrary exercise of judgment. Therefore, the CA had no jurisdiction to reverse the acquittal. The reinstated acquittal is immediately final and executory.