Case Digest (G.R. No. 219952)
Facts:
People of the Philippines v. Jehlson Aguirre y Arididon, et al., G.R. No. 219952, November 20, 2017, First Division, Tijam, J., writing for the Court.The prosecution (the People) charged accused-appellants Jehlson Aguirre y Arididon, Michael Arabit y Pacamara, Jefferson Paralejas y Pigtain and Jeffrey Roxas y Aragoncillo with Qualified Trafficking in Persons under Sections 3(a), 4(a) and 6 of Republic Act No. 9208 (Anti‑Trafficking in Persons Act of 2003), in relation to RA 7610, for recruiting, transporting, harboring, providing or receiving ten women (including minors) for prostitution and sexual exploitation.
Four of the ten girls (private complainants AAA, BBB, CCC and DDD) testified that on November 16, 2010 they were induced to go swimming/drinking and to have sex with foreigners in exchange for money and/or shabu. Their accounts described gatherings at Arabit’s house, assembly of the ten girls, boarding of a white van, transport to a two‑storey apartment in Quezon City, instructions by the accused to primp and not leave, offers of what appeared to be shabu as payment for sex, and statements promising travel abroad. Police from the CIDG‑WCPD, acting on information from a civilian informant associated with a TV program, staged a raid and arrested the accused; the girls were referred to social workers. The accused denied the charges, claiming they were mere invitees to a swimming/drinking party.
At the Regional Trial Court (Quezon City, Branch 106), the RTC rendered a Judgment dated May 28, 2013 convicting Aguirre, Arabit and Paralejas of Qualified Trafficking; each was sentenced to life imprisonment and a P2,000,000 fine, and ordered to pay AAA, BBB, CCC and DDD moral and exemplary damages (P100,000 and P50,000 respectively). The RTC did not convict under RA 7610 and acquitted Roxas. The accused‑appellants appealed to the Court of Appeals (CA).
The CA, in a Decision dated August 29, 2014 (CA‑G.R. CR‑H.C. No. 06220), affirmed the RTC’s conviction but modified the damages award to make the accused jointly and severally lia...(Subscriber-Only)
Issues:
- Whether the prosecution proved beyond reasonable doubt that the accused‑appellants committed Qualified Trafficking in Persons.
- Whether the private complainants’ testimony as to statements made by the accused‑appellants is inadmissible hearsay.
- Whether the absence of foreigners or proof that the apartment was a brothel defeats a trafficking conviction.
- Whether the minority of the complainants constituted a qualifying circumstance for Qualified Trafficking given the allegations in the Information.
- Whether subsidiary imprisonment for nonpayment of the fine may be i...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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