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102. Case Title: Raya v.

People,
G.R. No. 237798, May 5, 2021
Syllabi Class: Double jeopardy

Q: X & Y were charged with Qualified Trafficking in Persons. After Republic A rested its case, X
& Y filed a Motion for Leave to File Attached Demurrer to Evidence with attached Demurrer to
Evidence to which Republic A filed its Comment/Opposition thereto. The RTC then issued the
Resolution granting the Demurrer on the ground that, based on its assessment, the testimonies
of the prosecution witnesses were plagued with inconsistencies. The witnesses for the
prosecution showed various discrepancies, inconsistencies and contradiction between their
testimonies in court and their affidavits. The presumption of regularity in the performance of the
official duties of said policemen was ruined by their own contradicting testimonies and
irregularities which erode the credence of their declarations. Taken as a whole, the sum total of
the evidence presented by the prosecution against the two (2) accused are not enough to
sustain conviction, even if unrebutted. Disagreeing with the RTC, Republic A, filed a petition for
certiorari before the CA, alleging grave abuse of discretion amounting to lack or excess of
jurisdiction in the RTC's issuance of the Resolution granting the Demurrer. The CA granted the
petition for certiorari and reversed the acquittal made by the RTC. The CA also noted that the
RTC granted the demurrer because witness Z supposedly did not testify that she was "recruited,
obtained, (acquired), hired, provided, offered and transported x x x to be engaged by another in
sexual intercourse or lascivious conduct in exchange for money, profit or other consideration by
either or both accused X & Y. The CA thus declared null and void the RTC's Resolution granting
the Demurrer, and ordered the case reinstated for continuation of the proceedings. Was X & Y’s
right against double jeopardy violated?

A: Yes. The grant of the Demurrer cannot be reversed without offending X & Y's constitutional
right against double jeopardy. Article III, Section 21 of the 1987 Constitution provides that "no
person shall be twice put in jeopardy of punishment for the same offense. If an act is punished
by a law and an ordinance, conviction or acquittal under either shall constitute a bar to another
prosecution for the same act." This is what is otherwise known as the right against double
jeopardy. To give life to the right against double jeopardy, the Court has, in numerous
occasions, adhered to the finality-of-acquittal doctrine, which provides that "a judgment of
acquittal, whether ordered by the trial or the appellate court, is final, unappealable, and
immediately executory upon its promulgation." The public interest in the finality of criminal
judgments is so strong that an acquitted defendant may not be retried even though the acquittal
was based upon an egregiously erroneous foundation. If the innocence of the accused has
been confirmed by a final judgment, the Constitution conclusively presumes that a second trial
would be unfair. Thus, the finality-of-acquittal rule has the same animus as the right against
double jeopardy. However, the finality-of-acquittal doctrine does not apply when the prosecution
- the sovereign people, as represented by the State - was denied a fair opportunity to be heard.
Simply put, the doctrine does not apply when the prosecution was denied its day in court - or
simply, denied due process.

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