G.R. No. 225288 - People vs. XXX

On May 31, 2005, the Philippine National Police’s CIDG in coordination with the International Justice Mission (IJM) conducted a coordinated rescue and entrapment operation at a bar (name redacted) where sex workers—several of whom were minors—were being exploited.
The operation was prompted by credible reports of prostitution and human trafficking activities at the establishment, which involved the recruitment and hiring of young women for sexual services.

Accused-appellants XXX and YYY were charged with Qualified Trafficking in Persons under Sections 4(a)(e) and 6(a)(c)(f) of Republic Act (RA) 9208, in relation to Section 3 thereof and applicable provisions of RA 9231 amending RA 7610.
The information alleged that on the night of May 31, 2005, the accused, acting in concert as a syndicate, recruited, hired, and trafficked approximately eleven young women—including a minor (AAA, aged 16/17 years)—for the purposes of prostitution and sexual exploitation.
It was further alleged that XXX, who is a police officer and owner of the bar, and YYY, acting in a managerial capacity, facilitated the practice by arranging for the transport, screening, and sale of the victims’ sexual services for a fee (notably, a “bar fine” of Php20,000.00 for four girls).

AAA, one of the underage victims, who detailed how she was recruited, her work conditions, and the arrangement for sexual services.
PO3 Anthony Ong, who conducted surveillance and later corroborated the presence of sexually explicit arrangements within the VIP rooms.
BBB, an undercover investigator from IJM, who provided detailed accounts of his interactions at the establishment, including being shown the VIP rooms and witnessing transactions.
Other corroborative witnesses including a police inspector, a forensic chemist, and a Department of Social Welfare and Development (DSWD) social worker.

Video recordings of the surveillance operations on May 26 and May 31, 2005, showing transactions and the layout of the establishment including the VIP rooms.
Evidence of marked money paid by BBB to XXX, later confirmed by forensic tests detecting the presence of a yellow powder.
Official records such as the bar’s business permit in XXX’s name and other documentary evidence establishing his ownership and administrative control.

Accused-appellants XXX and YYY categorically denied involvement in any trafficking or prostitution activities.
XXX claimed that the money received was a reservation or “bar fine” and contended that he was not aware of AAA’s minority, asserting that she had at one point indicated she was of legal age.
YYY described himself as merely an errand boy with no authority or knowledge over the transactions; he attributed the organization and operational control to a co-accused known as “Mommy Angel.”
AAA, despite her initial testimony implicating the accused, later recanted portions of her testimony during subsequent proceedings, claiming that XXX and YYY did not exercise control over her work or involvement in the alleged prostitution.

The Regional Trial Court (RTC) of Manila, Branch 9, in its September 17, 2009 decision, found XXX and YYY guilty beyond reasonable doubt for Qualified Trafficking in Persons.
The RTC sentenced both accused to life imprisonment and imposed a fine of Php2,000,000.00, basing its findings principally on the cumulative and corroborative evidence presented by the prosecution.
The Court of Appeals (CA) later affirmed the RTC decision, holding that all elements of the offense had been satisfactorily established, including the victim’s minority, the nature of the bar’s operations, and XXX’s status as a police officer.

Despite the recantation by witness AAA in subsequent testimony, the trial and appellate courts accorded greater credence to the corroborated evidence, notably the video recordings, physical evidence (marked money), and the testimonies of undercover operatives and law enforcement personnel.
In addition to upholding the conviction, the final decision awarded moral damages of Php500,000.00 and exemplary damages of Php100,000.00 (with interest at six percent per annum) to AAA, recognizing that as a minor she could not validly consent to the exploitation.

Whether the prosecution’s cumulation of testimonial, documentary, and physical evidence was sufficient to establish beyond reasonable doubt that accused-appellants XXX and YYY orchestrated the recruitment, hiring, and trafficking of underage girls for prostitution and sexual exploitation.
Whether the recantation of testimony by the victim AAA undermines or negates the credibility of the evidence establishing the trafficking scheme and the involvement of the accused.
Whether the defense’s contention—that the evidence merely constituted inconsistent, uncorroborated accounts and that the accused lacked actual knowledge of the victim’s minority—holds merit in light of the corroborative evidence presented.
Whether the established fact that one of the accused is a police officer (thus qualifying the crime under Section 6(f) of RA 9208) should weigh in affirming the conviction, despite the conflicting statements regarding the chain of control over the exploitation activities.