Case Digest (G.R. No. 270934) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In the case of People of the Philippines vs. Joemarie Ubanon y Man-an, alias "Jomare Francesco" or "Alex," the accused-appellant was charged and convicted for qualified trafficking in persons under Republic Act No. 9208, also known as the Anti-Trafficking in Persons Act, as amended by Republic Act No. 10364. On April 13, 2014, around noon, in Bukidnon, Philippines, Joemarie and co-accused Amirah Macadatar allegedly recruited, transported, and provided minors AAA270934 and BBB270934, both 14 years old, and CCC270934, 15 years old, under the pretext of domestic employment for the purpose of forced labor without their consent or proper compensation. The victims were approached while watching a Manny Pacquiao fight and were offered work peeling onions in a distant location for a supposed wage of PHP 2,500.00 monthly. Joemarie insisted they accompany him without allowing them to first seek their parents’ permission. The accused took the minor victims to a certain DDD’s house and even Case Digest (G.R. No. 270934) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Charges
- Joemarie Ubanon y Man-an (Joemarie) and Amirah Macadatar (Amirah) were charged with qualified trafficking in persons under Section 4, in relation to Sections 6(a) and 10(c) of Republic Act No. 9208, as amended by RA No. 10364.
- The charges stemmed from an incident on April 13, 2014, around noon, in Bukidnon, where the accused allegedly recruited and transported minors under false pretense for forced labor.
- The Crime and Mode of Operation
- The three private complainants (identified as AAA270934, BBB270934, and CCC270934), aged 14, 14, and 15 respectively, were approached by Joemarie while watching a Manny Pacquiao fight.
- Joemarie offered them jobs as onion peelers with a monthly wage of PHP 2,500, pressuring them to leave immediately without parental consent.
- He brought them to the house of Amirah’s daughter DDD, stayed with them, then accompanied them to a bus terminal to board a bus with DDD, eventually being taken to Marawi City where the complainants worked as unpaid domestic helpers.
- Testimonies and Evidence
- The private complainants provided testimonies describing the recruitment, transportation, and forced labor experienced.
- Birth certificates were presented to confirm the minors’ ages.
- Joemarie denied wrongdoing, claiming he merely referred the complainants to Amirah and advised them to seek parental permission.
- Trial and Initial Judgment
- The Regional Trial Court (RTC) found Joemarie guilty beyond reasonable doubt of qualified trafficking.
- Joemarie was sentenced to life imprisonment, fined PHP 2,000,000.00, and ordered to pay damages to the complainants.
- The charge against Amirah was archived pending her arrest.
- Appeal
- Joemarie appealed the conviction, arguing lack of evidence proving his participation in transporting the victims.
- The Court of Appeals (CA) affirmed the RTC’s decision but deleted the disqualification for parole.
- Supreme Court Review
- The Supreme Court took cognizance of the appeal to review the sufficiency of evidence and correctness of the conviction and penalties.
Issues:
- Whether or not Joemarie Ubanon y Man-an is guilty beyond reasonable doubt of qualified trafficking in persons under Republic Act No. 9208, as amended.
- Whether the prosecution sufficiently established Joemarie’s active participation in recruiting and transporting the minor victims for forced labor.
- The correctness of the penalty and damages imposed by the lower courts.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)