G.R. No. 242473 - People vs. Adrian Adrales

Case Digest (G.R. No. 242473)
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Facts:

Nature of the appeal and challenged rulings
Adrian Adrales y Jurado (Adrales) filed an ordinary appeal seeking reversal of the Decision dated March 26, 2018 of the Court of Appeals (CA) in CA-G.R. CR HC No. 07727.
The CA Decision affirmed with modification the Joint Decision dated August 14, 2015 of Branch 207, Regional Trial Court (RTC) in Criminal Case Nos. 12-017, 12-018, and 12-019.
Both courts found Adrales guilty beyond reasonable doubt of three counts of qualified trafficking in persons under Section 4(a), in relation to Section 6(a) of Republic Act No. 9208 (RA 9208), the Anti-Trafficking in Persons Act of 2003.

Informations and qualifying circumstance
Criminal Case No. 12-017

Adrales was indicted for willfully and unlawfully recruiting, transporting, and transferring complainant “AAA,” a fourteen-year-old minor born on December 2, 1996, for the purpose of prostitution and sexual exploitation.
The Information alleged introduction of AAA to “Emong,” whose house in xxxxxx, xxxxxxxxxxx, Philippines was the place of sexual intercourse.
The Information alleged three separate occasions of sexual intercourse with Emong.
It alleged payment by Adrales after every sexual intercourse: PHP 800.00 initially and thereafter PHP 700.00 on the last two occasions for a total of PHP 2,000.00.
The qualifying circumstance alleged that AAA was still fourteen years old at the time of the incidents.

Criminal Case No. 12-018

Adrales was indicted for willfully and unlawfully recruiting, transporting, and transferring AAA, a fourteen-year-old minor born on December 2, 1996, for prostitution and sexual exploitation.
The Information alleged introduction of AAA to “Sir,” whose place in xxxxxxxxxxxxx located in xxxxxx, Muntinlupa, Philippines was the place of sexual intercourse.
It alleged two separate occasions of sexual intercourse with Sir.
It alleged payment by Adrales after every sexual intercourse: PHP 800.00 twice for a total of PHP 1,600.00.
The qualifying circumstance alleged AAA’s age of fourteen at the time of the incidents.

Criminal Case No. 12-019

Adrales was indicted for willfully and unlawfully recruiting, transporting, and transferring AAA, a fourteen-year-old minor born on December 2, 1996, for prostitution and sexual exploitation.
The Information alleged introduction of AAA to “Nan,” whose place in xxxxxxxxxxxxxxx located in xxxxxx, xxxxxxxxxxxxx, Philippines was the place of sexual intercourse.
It alleged three separate occasions of sexual intercourse with Nan.
It alleged payment by Adrales after every sexual intercourse: PHP 800.00, PHP 600.00, and PHP 400.00, respectively, for a total of PHP 1,800.00.
The qualifying circumstance alleged AAA was still fourteen years old at the time of the incidents.

Adrales pleaded not guilty to all charges upon arraignment on November 28, 2012.

Prosecution evidence: recruitment, repeated sexual exploitation, and payments
Meeting and initial recruitment

The prosecution alleged that sometime in July 2011, AAA, age fourteen, was walking along railroad tracks on her way home from a party when she met Adrales.
After asking AAA what time it was, Adrales introduced himself and invited her to come with him to the house of his friend named “Emong.”

First sexual exploitation with Emong

AAA and Adrales entered Emong’s house, ate and watched television.
Adrales and Emong later went out of the house, but only Emong returned shortly after.
AAA asked where Adrales went.
Emong started touching AAA’s legs.
AAA initially resisted, but Emong was persistent.
Emong held AAA’s arms, guided her to lie down, took off her shorts and underwear, and had sexual intercourse with her.
AAA stated the act was quick.
After the incident, Adrales returned and gave AAA PHP 800.00.

Second and third sexual exploitations with Sir

Enticed by money Adrales gave her, AAA once more went with Adrales to a “raket within the same month.”
This time, AAA met a man referred to as “Sir” or “Tutor.”
AAA had sexual intercourse with Sir together with her friend, Mae.
After the incident, AAA and Mae received PHP 700.00.
The sexual encounter with Sir was allegedly repeated.

Sexual exploitation with Hernan

A month after, in August 2011, Adrales introduced AAA to another friend named “Hernan.”
Hernan allegedly paid AAA PHP 800.00 for her “services” and also offered perfume and shoes or slippers as payment.
Similar to what happened with Emong and Sir, the sexual encounter with Hernan was repeated.

Trial and appellate reliance on circumstances

Both the RTC and the CA treated AAA’s testimony as direct, straightforward, and consistent.
Both courts observed that Adrales was with AAA before, during, and after sexual encounters and accompanied her each time to the places where exploitation occurred.
The courts considered the timing of money given to AAA after each incident as corroboration of Adrales’s role and purpose.

Minority proof

AAA’s minority was proven by the presentation of her Birth Certificate.

Defense evidence and theory
Denial and alternative explanations

Adrales vehemently denied the charges.
He claimed AAA knew Emong, Sir, and Hernan, and that AAA and Hernan were in a relationship.
He asserted he realized AAA was engaged in prostitution only after hanging out with her almost every night.
He maintained he had nothing to do with it, and that AAA was already well-known in their place as a woman of ill-repute (a “pokpok” or “pila-balde”).

Alleged dissociation and barangay proceedings

Adrales averred he dissociated from AAA after rumors began spreading that he was the latter’s pimp.
He asserted surprise when he was arrested by the police three months after he and AAA’s sister agreed during barangay proceedings that he would no longer communicate with AAA in exchange for the withdrawal of the complaint for trafficking filed by AAA and her sister.

Testimony of Raquel Constantino

The defense presented Raquel Constantino (Raquel), asserted to be the wife of Hernan.
Raquel testified she did not believe AAA’s statement that she was being pimped by Adrales because she allegedly knew Adrales for more than 10 years.
Raquel added that her husband admitted to her that he and AAA were in a relationship two months before AAA first met Adrales.

RTC Joint Decision (August 14, 2015)
Conviction and sentencing

The RTC found Adrales guilty beyond reasonable doubt of three counts of qualified trafficking in persons.
The RTC convicted Adrales under Section 6(a) in relation to Section 4(a) of RA 9208 for Criminal Cases 12-017, 12-018, and 12-019.
The RTC sentenced Adrales to three (3) life impri...(Subscriber-Only)

Issues:

Principal issue on criminal liability
Whether the CA erred in affirming Adrales’s conviction for qualified trafficking in persons under Section 4(a), in relation to Section 6(a) of RA 9208.

Sub-issues raised by Adrales
Whether courts a quo erred in giving credence to AAA’s testimony while rejecting Adrales’s denial.
Whether the prosecution failed to prove all elements of the crime charged.
Whether the prosecution failed to prove that Adrales committed the acts for the purpose of exploiting or prostituting AAA.
Whether evidence showed AAA was publicly known as a “pila-balde” and engaged in sexual acts without coercion, influence, or pressure from anyone.
Whether courts a quo failed to consider Adrales’s claim that he never received payment or commission because AAA received payments directly from customers, and because he only accompanied AAA due to her offer of free drinks and food.
Whether the presumption of innocence required reversal due to alleged insufficiency of prosecution evidence.
Whether denial was improperly treated as automatic...(Subscriber-Only)

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