Title
Supreme Court
People vs. Vergel CaAas y Ganalon
Case
G.R. No. 267360
Decision Date
May 15, 2024
Accused Vergel CaAas y Ganalon was convicted of three counts of qualified trafficking in persons for exploiting a minor through prostitution. The Supreme Court affirmed the lower court's decision with modified penalties.

Case Digest (G.R. No. 267360)
Expanded Legal Reasoning Model

Facts:

  • Charges and Consolidation
    • Vergel CaAas y Ganalon (hereafter CaAas) was charged with three counts of qualified trafficking in persons under Section 4(a) in relation to Section 6(a) of Republic Act No. 9208, as amended by Republic Act No. 10364.
    • The three Informations allege that CaAas recruited, offered, and transported a 13-year-old minor, AAA, with the assistance of her mother BBB, for purposes of sexual exploitation at various locations including Victoria Court, a condominium near Rizal Coliseum, and Imus, Cavite.
    • The three criminal cases were consolidated by the Regional Trial Court (RTC).
  • Events and Incidents Leading to Charges
    • AAA ran away from home and was staying with her friend Alrose in Pampanga.
    • CaAas contacted Alrose, offering "work" opportunities involving sexual services.
    • On April 6, 2016, April 9, 2016, and April 16, 2016, CaAas brought AAA to clients where she was made to render sexual services in exchange for money, with CaAas taking a commission.
    • AAA was only 13 years old during these incidents.
  • Trial Testimonies
    • AAA narrated in detail the three incidents including being given clothes and makeup, being introduced to clients by CaAas, and being coerced or required to perform sexual acts in exchange for money.
    • CaAas denied the charges, claimed limited interaction, and alleged that the mother of AAA demanded money to withdraw the case, which he paid.
  • RTC Decision
    • The RTC found CaAas guilty beyond reasonable doubt of three counts of qualified trafficking in persons.
    • CaAas was sentenced to life imprisonment and fined PHP 2,000,000.00 per count.
    • He was ordered to indemnify the private complainant the amounts for moral and exemplary damages.
  • Court of Appeals (CA) Decision
    • The CA affirmed the RTC decision with a modification reducing exemplary damages.
  • Present Appeal
    • CaAas appealed to the Supreme Court, alleging failure of proof by the prosecution and issues with the credibility of AAA's testimony.

Issues:

  • Whether the prosecution proved beyond reasonable doubt the guilt of CaAas for three counts of qualified trafficking in persons under Republic Act No. 9208, as amended.
  • Whether the trial court erred in finding AAA a credible witness despite alleged inconsistencies in her testimony.
  • Whether the acts of recruitment, harboring, and exploitation were established.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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