Case Digest (G.R. No. 234365)
Facts:
In People of the Philippines v. Susan Sayo y Reyes and Alfredo Roxas y Sagon (G.R. No. 227704, April 10, 2019), the respondents were indicted on November 15, 2005 in Pasig City for violating the Anti-Trafficking in Persons Act of 2003 (RA 9208). The Information charged Susan Sayo with recruiting and transporting three women—minors AAA (15) and BBB (16) and adult CCC—for prostitution, while Alfredo Roxas was accused of owning and operating a room used as a prostitution den, receiving and harboring those trafficked persons, and profiting from condom sales. After arraignment, both pleaded not guilty. The prosecution presented testimonies of the three “plaza girls,” birth certificates establishing minority, and detailed an “Oplan Sagip Angel” entrapment by CIDG-WCCD and the International Justice Mission, culminating in the arrest on November 15, 2005 and recovery of marked money. The RTC, Pasig City, Branch 261, convicted both for qualified trafficking and trafficking in persons, imCase Digest (G.R. No. 234365)
Facts:
- Indictment and Arraignment
- On November 15, 2005 in Pasig City, the Information charged Susan Sayo y Reyes (Sayo) with recruiting and transporting minors AAA (15) and BBB (16), and adult CCC, for prostitution and sexual exploitation, and charged Alfredo Roxas y Sagon (Roxas), in conspiracy with Sayo, with owning and operating a room as a prostitution den.
- Both accused-appellants pleaded not guilty at arraignment.
- Prosecution Evidence
- Testimonies of AAA, BBB and CCC established that from December 2004 to November 2005 they were under Sayo’s control as “plaza girls.” Sayo acted as pimp, collecting ₱50 per customer; Roxas rented a room for ₱100 per 30 minutes and sold condoms at ₱30.
- “Oplan Sagip Angel” entrapment: Investigators and IJM agents posed as customers on November 15, 2005. Sayo introduced the minors; group proceeded to Roxas’s apartment; marked money (₱300 room fee, ₱900 service fee) was handed over; agents signaled raid; both accused were arrested and marked bills recovered.
- Defense Evidence
- Sayo claimed she was misled by CCC and the men, agreed to go to Roxas’s house for ₱100, and was unexpectedly arrested.
- Roxas testified he was asleep, refused to rent the room until the men forced marked money upon him; admitted knowing CCC, AAA and BBB for months but denied facilitating prostitution.
- RTC Decision (September 23, 2010)
- Held the Information duplicitous but waived; convicted Sayo and Roxas of Qualified Trafficking in Persons under Sections 4, 5 and 6 of RA 9208.
- Sentenced both to life imprisonment and ₱2,000,000 fine for minors (AAA, BBB); additional penalties for CCC (20 years/₱1,000,000 for Sayo; 15 years/₱500,000 for Roxas).
- CA Decision (June 26, 2015)
- Affirmed RTC with modifications: added moral damages of ₱500,000 and exemplary damages of ₱100,000 each for AAA and BBB; omitted damages for CCC.
- Maintained same conviction and penalties for both appellants.
- Appeal and Subsequent Events
- Accused-appellants filed Notice of Appeal on July 30, 2015; briefs waived.
- Certification dated May 12, 2017 revealed Sayo’s death on November 30, 2011 due to cervical cancer.
Issues:
- Whether Roxas’s guilt was proven beyond reasonable doubt.
- What is the legal effect of Sayo’s death on her criminal and civil liability.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)