Title
People vs. Gumba and Rellama
Case
G.R. No. 260823
Decision Date
Jun 26, 2023
The Supreme Court affirmed the conviction of Gumba and Rellama for qualified trafficking of minors for prostitution, validating a police entrapment operation and ordering life imprisonment plus damages.

Case Digest (G.R. No. 260823)
Expanded Legal Reasoning Model

Facts:

  • Background and Charge
    • Rizalina Janario Gumba ("Mommy Riza") and Gloria Bueno Rellama ("Mommy Glo"), floor managers of a bar in Cavite, were charged with qualified trafficking of persons, specifically trafficking minors for prostitution, under Section 4(a) in relation to Section 6(a) of Republic Act No. 9208 as amended (Anti-Trafficking in Persons Act of 2003 and the Expanded Act of 2012).
    • The Information alleged that on or about October 22, 2014, Gumba and Rellama conspired to hire, offer, and sell young girls, including minors aged 15 and 18, for sexual intercourse with male customers at fees ranging from PHP 1,500 to PHP 2,000 per girl per transaction.
    • The crime was qualified by the minority of some victims (AAA and BBB, aged 15), as established by birth certificates.
  • Police Investigation and Entrapment Operation
    • Police Superintendent Harris R. Fama directed Police Officer 3 Christopher Artuz (PO3 Artuz) to conduct surveillance of the bar following a tip that prostitution was occurring.
    • On October 10, 2014, disguised as customers, PO3 Artuz and undercover agents confirmed that Gumba and Rellama offered girls for sexual services charged at PHP 1,500 per girl.
    • PO3 Artuz submitted an After Surveillance Report; based on it, a rescue and entrapment operation was planned with coordination among various police and social welfare units.
    • For the entrapment, PO3 Artuz contacted Gumba posing as a client needing 15 girls for a party, agreeing to pay PHP 1,500 per girl.
  • October 22, 2014 Operation and Arrest
    • On the agreed date, Gumba and Rellama brought AAA, BBB, and six other girls, including minors, to the meeting point; all boarded PO3 Artuz's van.
    • During transit, Gumba bought and distributed condoms to the girls.
    • Gumba increased the price to PHP 2,000 per girl due to their youth, and accepted marked money from PO3 Artuz, distributing PHP 1,500 to each girl.
    • The entrapment and rescue team arrested Gumba and Rellama at a predetermined location.
    • Rescued minors and other girls testified that Gumba and Rellama acted as their "bugaw" (pimps), regularly offering them to customers for paid sexual services.
  • Trial and Defense
    • Gumba and Rellama pleaded not guilty and testified they only provided entertainers who would mingle socially without sexual services, denying receiving marked money.
    • They argued that the crime was not consummated as no paid sex occurred at the time of arrest and claimed the police operation was instigation rather than entrapment.
  • Judicial Proceedings
    • The Regional Trial Court (RTC) convicted Gumba and Rellama beyond reasonable doubt, giving weight to victim testimonies and holding the crime consummated upon recruitment and provision of the girls for paid sex.
    • The RTC declared the police operation valid entrapment under both subjective and objective standards.
    • The Court of Appeals affirmed the conviction and awarded moral and exemplary damages to victims.
    • The case was elevated to the Supreme Court on appeal by Gumba and Rellama.

Issues:

  • Whether the prosecution sufficiently established all elements of qualified human trafficking involving minors for prostitution under Sections 4(a) and 6(a) of Republic Act No. 9208, as amended.
  • Whether the crime was consummated despite no actual sexual intercourse occurring at the time of arrest.
  • Whether the police operation constituted valid entrapment or unlawful instigation.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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