Title
People vs. Marivic Saldivar y Regatcho
Case
G.R. No. 266754
Decision Date
Jan 29, 2024
Court upheld the conviction of Marivic Saldivar for trafficking a minor into prostitution, affirming life imprisonment and increased moral damages to PHP 500,000.

Case Digest (G.R. No. 266754)
Expanded Legal Reasoning Model

Facts:

  • Background and Charges
    • Marivic Saldivar y Regatcho was charged with violation of Section 4(a), qualified by Section 6(a) of Republic Act No. 9208, as amended by Republic Act No. 10364, for human trafficking.
    • The Information alleged that between March 2016 and May 2017, Saldivar took custody of a 14-year-old minor street child, referred to as AAA266754, for the purpose of prostitution and sexual exploitation by acting as procurer.
  • Trial Proceedings and Testimonies
    • Upon arraignment, Saldivar pleaded not guilty.
    • The minor, AAA266754, testified that she ran away from home and was introduced to Saldivar, with whom she lived.
    • Saldivar reportedly pimped AAA266754 to men who also bought drugs from her, receiving money before the minor's sexual abuse.
    • The abuse lasted for about a year until the minor was rescued by the Emergency Welfare Section.
    • Social Welfare Officer I Genesis M. Panganiban interviewed Saldivar, who claimed the minor chose to subject herself to prostitution and handed the money earned to her.
    • Saldivar admitted to sometimes directing men to the minor but insisted it was the minor's decision to accept or decline offers.
  • Medical and Defense Evidence
    • Dr. Voltaire P. Nulud issued a Medico-Legal Report showing deep healed lacerations and blunt penetrating trauma to the minor's hymen.
    • Saldivar denied the charges, asserting that the minor engaged voluntarily in prostitution and that she was angry at Saldivar for asking her to leave.
    • Saldivar alleged a motive for fabrication by social welfare officers who had previously filed complaints against her.
  • Court Decisions
    • The Regional Trial Court (RTC) found Saldivar guilty beyond reasonable doubt, noting the minor's credible testimony.
    • Saldivar was convicted of qualified trafficking in persons due to the minor's age.
    • The RTC sentenced Saldivar to life imprisonment, imposed a PHP 2,000,000 fine, and ordered payment of PHP 50,000 moral damages to the victim.
    • On appeal, the Court of Appeals (CA) affirmed the conviction but increased moral damages to PHP 500,000 with interest.
    • The CA held that the minor's testimony was credible and that the absence of an entrapment operation did not negate the evidence.
  • Appeal to the Supreme Court
    • Saldivar contested the conviction citing inconsistencies in the minor’s testimony and the absence of an entrapment operation.
    • The Supreme Court took the case for final resolution.

Issues:

  • Whether the Court of Appeals correctly affirmed the conviction of Marivic Saldivar y Regatcho for qualified trafficking in persons under Republic Act No. 9208, as amended.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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