Case Digest (G.R. No. 235652) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. XXX and YYY (G.R. No. 235652, July 9, 2018), the spouses XXX and YYY were charged before the Regional Trial Court (RTC), Branch 25 of Biñan, Laguna in Criminal Case Nos. 21802-B, 21803-B, 21804-B and 24608-B under Republic Act No. 9208 (the Anti-Trafficking in Persons Act of 2003). The first three Informations alleged that between 2008 and 2011 in Cabuyao, Laguna, the couple, as biological parents and legal guardians, conspired to exploit their three minor children—AAA (14 years), BBB (10 years) and CCC (9 years)—by inducing them to perform simulated sexual acts and nude dances via webcam before foreign clients, in exchange for fees collected by the father. The fourth Information charged XXX alone with transporting AAA to Makati City for sexual intercourse with a foreigner in exchange for ₱100,000. In February 2011, AAA sought help from the DSWD; the NBI executed a search warrant, rescuing the children and arresting the parents. At trial, the RTC, Case Digest (G.R. No. 235652) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Origin and Charges
- Four Informations (Criminal Cases Nos. 21802-B, 21803-B, 21804-B, 24608-B) were filed before the Regional Trial Court (RTC) of Biñan, Laguna, charging XXX and YYY (and John Doe in one case) with Qualified Trafficking in Persons under Section 4(e) in relation to Section 6(a) and (d) of RA 9208.
- Criminal Case No. 21802-B: From 2008 until March 5, 2011, accused-parents conspired to maintain their minor daughter AAA (born December 14, 1996) for prostitution/pornography by webcam, inducing her to show her genitals, breasts and perform explicit acts for paying foreign viewers.
- Criminal Case No. 21803-B: In 2010 up to March 5, 2011, parents similarly exploited minor BBB (born May 14, 2000), having her dance naked and show private parts via webcam to a usual client “Sam” for a fee.
- Criminal Case No. 21804-B: In 2010 up to March 5, 2011, parents subjected minor CCC (born July 24, 2001) to identical cyber-exploitation sessions for foreign payers.
- Criminal Case No. 24608-B: Sometime in April 2010, XXX transported AAA to a Makati hotel, facilitating her sexual intercourse with a foreigner, John Hubbard, in exchange for ₱100,000.
- Investigation and Evidence
- AAA sought DSWD assistance in February 2011; DSWD coordinated with the NBI, which secured and executed a search warrant, rescued the three children, seized computer equipment, and arrested XXX and YYY.
- Victim-testimonies: AAA, BBB and CCC identified their parents as perpetrators, described the ordered acts of cybersex and the collection of earnings by YYY at remittance centers.
- Defense and Lower Courts’ Decisions
- Defense: Accused-appellants denied the charges, alleged AAA ran away after an out-of-wedlock pregnancy, and disputed seizure of computers.
- RTC Judgment (Oct. 23, 2015): Convicted both of four counts of Qualified Trafficking; imposed life imprisonment, ₱2,000,000 fine per count, and ₱30,000 moral plus ₱10,000 exemplary damages per count.
- CA Decision (Aug. 25, 2017): Affirmed with modifications—reduced YYY’s counts to three, increased damages to ₱500,000 moral and ₱100,000 exemplary per count.
Issues:
- Whether XXX and YYY are guilty beyond reasonable doubt of four and three counts, respectively, of Qualified Trafficking in Persons under Sections 4 and 6 of RA 9208.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)