Case Digest (G.R. No. 248694)
Facts:
People of the Philippines v. Ranie Estonilo y De Guzman, G.R. No. 248694 (October 14, 2020), promulgated December 26, 2022, Supreme Court Second Division, Perlas‑Bernabe, J., writing for the Court.The case arose from two separate Informations filed in the Regional Trial Court (RTC), Criminal Case Nos. 10‑5894 and 10‑5895, charging Ranie Estonilo y De Guzman with Qualified Trafficking in Persons under Section 4 in relation to Section 6(a) of RA 9208 (Anti‑Trafficking in Persons Act of 2003). The accusatory paragraphs alleged that between March 6 and March 13, 2010, Estonilo recruited, harbored, maintained, provided and/or received two minors—referred to as AAA (12 years old) and BBB (11 years old)—for the purpose of sexual exploitation.
Prosecution evidence described how Estonilo approached AAA in January 2010, attempted to induce him to sell sex, even introducing a prospective “client” who offered P2,000; AAA initially refused. On March 6, 2010, while AAA and BBB were walking home, Estonilo allegedly coerced them to perform sexual acts on one another in exchange for money (P300). About a week later, on March 13, 2010, Estonilo again allegedly arranged for the minors to have sexual contact at a bathroom after calling AAA; AAA thereafter developed pain on urination, was medically examined and diagnosed with an infection consistent with anal intercourse, and disclosed the incidents to his mother. Estonilo denied knowing the victims and claimed alibis (hotel maintenance work on weekdays and a carinderia on weekends).
In a Judgment dated July 28, 2016, the RTC found Estonilo guilty beyond reasonable doubt of two counts of Qualified Trafficking and sentenced him to life imprisonment, a fine of P2,000,000.00 for each count, and awarded AAA and BBB P20,000.00 each as moral damages. Estonilo appealed to the Court of Appeals (CA).
By Decision dated November 23, 2017, the CA modified the RTC judgment: it concluded that while Estonilo had coerced the minors for monetary consideration, the evidence did not establish trafficking as defined in RA 9208 (because the CA found no proof of recruitment/endorsement to a third‑party client). Applying the variance doctrine, the CA instead convicted him of two counts of violation of Section 5(a)(5), Article III of RA 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination), sentencing him to an indeterminate term of 14 years and 8 months to 20 years of reclusion temporal for each count and ordering P50,000.00 civil indemnity to each victim.
Estonilo brought the present appeal to the...(Subscriber-Only)
Issues:
- Was the mode of appeal properly taken to the Supreme Court?
- Did the prosecution prove beyond reasonable doubt that Estonilo committed Qualified Trafficking in Persons under Section 4(a) in relation to Section 6(a) of RA 9208?
- If convicted of Qualified Trafficking, what are the proper penalties ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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