Case Digest (G.R. No. 201292)
Facts:
This case involves the conviction of Ria Liza Bautista y Cariaga (Bautista) for qualified trafficking in persons under Republic Act No. 9208, as amended by Republic Act No. 10364. The incident took place in November 2017. The victim, identified as AAA270003, was a 14-year-old female minor at the time of the offense. Bautista was charged with recruiting, obtaining, hiring, offering, and transporting the minor by means of fraud, deception, and taking advantage of her vulnerability for the purpose of prostitution and sexual exploitation. At the Regional Trial Court (RTC), Bautista pleaded not guilty, but was found guilty beyond reasonable doubt and sentenced to life imprisonment with a fine of PHP 2 million. The RTC also awarded the victim moral and exemplary damages. The Court of Appeals (CA) affirmed the RTC's decision with modification to impose interest on the damages. Bautista elevated the case to the Supreme Court, appealing her conviction.The factual background revealed th
Case Digest (G.R. No. 201292)
Facts:
- Background and Charges
- Ria Liza Bautista y Cariaga (hereinafter "Bautista") was charged with qualified trafficking in persons under Republic Act No. 9208, as amended by Republic Act No. 10364.
- The accusatory portion stated that Bautista recruited, obtained, hired, offered, and transported AAA270003, a 14-year-old female minor, by means of fraud and deception, exploiting her vulnerability for the purpose of prostitution and sexual exploitation for profit.
- Investigation and Trial
- Bautista pleaded not guilty upon arraignment. Trial ensued after pre-trial.
- Admission and testimonies revealed AAA270003 was a minor at the time of the incidents.
- AAA270003 recounted the following:
- On November 16, 2017, an unknown caller, later identified as Bautista, contacted her.
- On November 23, 2017, AAA270003 met Bautista at Bautista’s boarding house and was subsequently pimped out to different men with Bautista and her companion Nicole.
- On November 24, 2017, Bautista pimped AAA270003 to a former soldier who sexually abused her and paid Bautista PHP 1,500, from which AAA270003 received PHP 1,000.
- On the following day, Bautista arranged another customer at a hotel; AAA270003 attempted but escaped due to pain, receiving PHP 700 from Bautista.
- In early November, Bautista introduced AAA270003 to Arnel and two other men; one of these men sexually abused AAA270003 and paid PHP 2,500, with PHP 500 going to Bautista.
- After the last incident, AAA270003 ceased association with Bautista.
- AAA270003 later informed her mother and filed a police report.
- Defense
- Bautista denied the accusations, claiming that AAA270003’s accusations stemmed from a dispute with Nicole.
- Lower Courts’ Decisions
- The RTC found Bautista guilty beyond reasonable doubt and sentenced her to life imprisonment, a fine of PHP 2,000,000, and ordered payment of moral and exemplary damages to AAA270003.
- The CA affirmed the RTC decision with modification, imposing a 6% interest per annum on damages from finality of judgment.
Issues:
- Whether Bautista is guilty beyond reasonable doubt of qualified trafficking in persons under Republic Act No. 9208, as amended.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)