Title
People vs. XXX
Case
G.R. No. 260639
Decision Date
Mar 29, 2023
NBI agents conducted an entrapment operation, arresting accused-appellant for trafficking minors. SC affirmed guilt, imposing life imprisonment and fines.

Case Digest (G.R. No. 260639)
Expanded Legal Reasoning Model

Facts:

  • Charges and Nature of the Case
    • Accused-appellant XXX was charged with Qualified Trafficking in Persons under Section 4 (a) and (e) in relation to Section 6 (a) and (c) of Republic Act No. 9208, as amended by RA 10364 (Anti-Trafficking in Persons Act of 2003).
    • The Information alleged that on or about January 28, 2014, accused-appellant, for purposes of prostitution and sexual exploitation, knowingly provided four minor children (AAA, BBB, CCC, and DDD, aged 15, 13, 17, and 16 years old respectively) as sexual service providers for a fee.
    • The qualifying circumstance of large scale trafficking was charged due to the involvement of four victims.
  • Investigation and Arrest
    • On January 27, 2014, the NBI Anti-Human Trafficking Division received information regarding sexual trafficking of minors at a specific mall.
    • Intelligence Agents Sarno and Natalia conducted surveillance and were approached by accused-appellant who offered them sexual services of minors at P1,000 per girl.
    • The agents returned and reported to Executive Officer Atty. Nuqui who ordered an entrapment and rescue operation scheduled on January 28, 2014.
    • During the operation, poseur customers agreed to pay for sexual services of the minors. Accused-appellant acted as pimp, instructing girls to offer services and receive a commission from earnings.
    • Accused-appellant was arrested while DSWD personnel rescued the minors.
  • Trial Proceedings
    • Accused-appellant pleaded "not guilty," and the trial court held pre-trial conferences, with admitted stipulations including identity confirmation and proper arrest.
    • The prosecution presented testimony from the complainants (victims AAA, BBB, CCC, and DDD) and intelligence agents involved in the operation, backed by documentary evidence such as affidavits, birth certificates, and marked money.
    • The defense presented accused-appellant’s testimony denying knowledge of or involvement in trafficking, asserting he was forcibly taken to the NBI office.
  • Lower Courts’ Decisions
    • The Regional Trial Court (RTC) found accused-appellant guilty beyond reasonable doubt, relying on credible and consistent testimonies of the victims positively identifying accused as the pimp.
    • The RTC sentenced accused-appellant to life imprisonment without parole and a fine of P2,000,000.
    • The Court of Appeals (CA) affirmed the RTC decision in 2020 but modified the monetary awards, ordering payment of moral and exemplary damages to each victim.
    • Accused-appellant appealed to the Supreme Court contesting the credibility of witnesses and the sufficiency of evidence.

Issues:

  • Whether the Court of Appeals correctly affirmed the Regional Trial Court’s finding of guilt beyond reasonable doubt of accused-appellant for Qualified Trafficking in Persons under Sec. 4 (a) and (e) in relation to Sec. 6 (a) and (c) of RA 9208, as amended by RA 10364.
  • Whether the qualifying circumstance involving the age of the victims (below 18 years old) is sufficiently proven and may be appreciated.
  • Whether the alleged inconsistencies in the testimonies of the prosecution witnesses affect their credibility and the guilt of accused-appellant.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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