G.R. No. 263603 - People vs. Eul Vincent O. Rodriguez

Eul Vincent O. Rodriguez was charged with qualified trafficking in persons involving a minor (AAA263603) under Section 4(a), in relation to Section 6 of Republic Act No. 9208, as amended by Republic Act No. 10364.
The criminal act allegedly occurred on or about February 13, 2014, where Rodriguez provided and transported a minor for the purpose of prostitution, acting as his procurer.
Rodriguez pleaded not guilty upon arraignment. Pre-trial stipulated facts included: the fact of Rodriguez’s arrest, the first police encounter at arrest, and prior online communication between procurer and decoy.

The US Immigration and Customs Enforcement (US ICE) informed Philippine authorities about Rodriguez’s involvement in human trafficking using social media accounts.
PSI Maria Macatangay, Regional Anti-Human Trafficking Task Force chief of Region 7, received information including a Skype account under the name “eula.rodriguez56.”
PO3 Jerry Gambi was delegated to validate this lead. He created a decoy Facebook account “Tristan James” to contact Rodriguez and identified Rodriguez’s Facebook account as “Bbyeuhan Rodriguez.”
PO3 Gambi conducted physical surveillance near Rodriguez’s residence in xxxxxxxxxxx but did not approach Rodriguez during initial encounters.
Communications between Rodriguez and the decoy began in January 2014. Rodriguez induced nude shows online involving minors, solicited money, and arranged such shows through Skype accounts “sofia.negra” and “cassandra.labajo.”
Multiple offers to present nude shows with minors aged 16 and 17 were made; these interactions were recorded via video and chat logs.
Payments to Rodriguez were remitted through Western Union to a third party per Rodriguez’s instructions.

On February 13, 2014, PO3 Gambi coordinated an entrapment operation with a confidential informant (CI) acting as “Kyle Edwards,” a supposed foreigner.
The CI booked a room at Waterfront Hotel; Rodriguez arrived with AAA263603 around 9:30 p.m.
SPO1 Timagos acted as the driver and delivered fluorescent powder-dusted marked money to Rodriguez, who accepted it after some hesitation.
Police arrested Rodriguez in flagrante delicto and seized marked money, a bag, a camera, a sex toy, cellphone, SIM cards, and money transfer receipts.
The dorsal and palmar sides of Rodriguez’s hands tested positive for fluorescent powder.

AAA263603, born September 10, 1999, was 14 years old at the time. He testified about performing about twenty nude shows under Rodriguez’s instruction.
Rodriguez arranged online communications with foreign customers and received money from their remittances.
On February 13, AAA263603 accompanied Rodriguez to the Waterfront Hotel but was eventually rescued by authorities.
Katrina Jane Marie Umali, a trauma assessor from the Women and Children Protection Center, testified that while no immediate trauma symptoms were observed, delayed psychological effects were possible.

Rodriguez denied the charges, claiming the hotel visit was merely to eat pizza with a foreigner and that AAA263603 was coached to testify by DSWD and the International Justice Mission (IJM).
He argued his right to due process was violated due to admission of chat logs and videos from communications preceding the charging incident.
He claimed illegal arrest and inadmissibility of seized evidence due to warrantless arrest and alleged forced acceptance of money (evidenced by fluorescent powder).
Trial court found prosecution witnesses credible and evidence sufficient, convicting Rodriguez of qualified trafficking.

Rodriguez appealed, contesting the admissibility of evidence, validity of arrest, and sufficiency of proof regarding the crime elements, emphasizing the lack of witnesses to the actual transaction.
He also asserted improper use of chat logs and videos violating privacy rights and the Anti-Wire Tapping Law.
The Court of Appeals affirmed the conviction, holding the arrest lawful, entrapment valid, and evidence admissible.
Motion for Reconsideration was denied by the CA.

Both parties adopted their CA arguments before the Supreme Court.
Rodriguez raised three main contentions: illegal arrest/instigation, inadmissibility of chat logs violating privacy, and failure to prove essential crime elements.

Whether Rodriguez’s arrest and the resulting seizure of evidence were lawful or constituted illegal arrest and “fruits of the poisonous tree.”
Whether the entrapment operation conducted by law enforcement was valid or amounted to instigation.
Whether the chat logs and video recordings are admissible evidence or violate constitutional rights and Republic Act No. 4200 (Anti-Wire Tapping Law).
Whether the prosecution sufficiently proved all elements of qualified trafficking in persons, considering alleged inability of witnesses to testify on the transaction and the victim’s psychological trauma.