Case Digest (G.R. No. 267609)
Facts:
The case involves Wilfreda Laput Campos, also known as Freda, who was the owner of Freda's KTV Bar located in Cebu, Philippines. On November 7, 2014, Campos was charged with qualified trafficking in persons involving three victims—AAA, BBB, and CCC, the latter being a minor aged 16 at the time—under Republic Act No. 9208, as amended by Republic Act No. 10364 (the Anti-Trafficking in Persons Act). The prosecution accused Campos of recruiting, obtaining, hiring, and offering the victims for sexual exploitation through the payment of a "bar fine". NBI Agent Rey Villordon and other officers conducted a surveillance and entrapment operation, posing as clients who paid Campos PHP 4,000 for three girls to be taken out for sexual services. Campos denied knowledge of CCC’s minority and claimed that the girls only went out to eat with the customers. The Regional Trial Court convicted Campos of qualified trafficking. The Court of Appeals affirmed this decision, and Campos appealed to the SCase Digest (G.R. No. 267609)
Facts:
- Parties and Charges
- Wilfreda Laput Campos, also known as "Freda," was charged with qualified trafficking of persons under Sections 4(a) and (e) in relation to Sections 6(a) and (c) of Republic Act No. 9208, as amended by Republic Act No. 10364 (Anti-Trafficking in Persons Act of 2003, as amended).
- The Information alleged that on November 7, 2014, Campos, owner of "Freda's KTV Bar" in Cebu, obtained, harbored, hired, maintained and/or provided three victims, including a minor (CCC, 16 years old), using means of fraud, deception, and taking advantage of vulnerability for purposes of prostitution and sexual exploitation.
- The crime was alleged to have been committed on a large scale and with a child victim, qualifying the offense.
- Proceedings and Evidence
- Campos pleaded not guilty at arraignment.
- During pre-trial, parties agreed Campos owned the bar and that CCC was a minor, though Campos claimed no knowledge of CCC's minority.
- Prosecution presented witnesses including NBI Agent Rey Villordon and the victims AAA, BBB, and CCC. AAA was related to the accused's family and the victims.
- Surveillance operations in October 2014 involved undercover agents posing as customers who paid bar fines to take out the girls, including CCC, suspected to be minors.
- On November 7, 2014, a planned entrapment and rescue operation was conducted; Agent Villordon acted as poseur buyer and paid marked money to Campos for taking the three girls out for sex.
- Campos was arrested in flagrante delicto upon receiving marked money. Positive forensic test for fluorescent powder was conducted.
- The victims testified about recruitment, working at the bar due to financial difficulties, executives of who decided on customer entertainment, and the implied nature of going out as sexual services.
- Campos denied authorizing sexual engagements, claimed the bar fines covered meals, and asserted recruitment and management were by others.
- Trial Court's Judgment
- On January 12, 2018, the RTC found Campos guilty beyond reasonable doubt of qualified trafficking based on evidence and testimony.
- The Court ruled actual sexual intercourse was not required; soliciting girls for sex and acceptance of payment sufficed.
- Campos was sentenced to life imprisonment without eligibility for parole and ordered to pay fines and damages.
- Appeal
- Campos appealed to the Court of Appeals; the OSG did not file an appellee's brief.
- The Court of Appeals affirmed the RTC judgment on January 27, 2021.
- It held that recruitment, means (taking advantage of minority and vulnerability), and purpose (sexual exploitation for money) were proven.
- Testimonies of victims and the NBI agent corroborated each other.
- The accused’s claimed ignorance of CCC’s age was held inconsequential.
- Supreme Court Proceedings
- Campos filed a Notice of Appeal to the Supreme Court; supplemental briefs were required.
- Accused-appellant argued prosecution only showed that customers took girls out to eat, not for sex, and that evidence was insufficient particularly lacking victim testimony implicating Campos.
Issues:
- Whether accused-appellant Wilfreda Laput Campos is guilty beyond reasonable doubt of qualified human trafficking under Sections 4(a) and (e) in relation to Sections 6(a) and (c) of R.A. 9208, as amended.
- Whether actual sexual intercourse between the victims and customers is required to establish the crime of trafficking in persons.
- Whether Campos's claimed ignorance of the victim CCC's minority exempts her from liability for qualified trafficking.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)