Title
Supreme Court
People vs. XXX
Case
G.R. No. 252230
Decision Date
Oct 5, 2022
XXX convicted of Qualified Trafficking for sexually exploiting minor AAA, proven through valid entrapment, victim testimony, and evidence; life imprisonment imposed.

Case Digest (G.R. No. 125986)
Expanded Legal Reasoning Model

Facts:

  • Background
    • The accused-appellant, XXX, was charged with Qualified Trafficking in Persons under Section 4(e), in relation to Section 6(a) of R.A. No. 9208, as amended by R.A. No. 10364.
    • The crime involved the maintenance and harboring of a 10-year-old minor, AAA, by offering and peddling her for sexual services in exchange for money.
    • The victim, AAA, was the niece of the accused-appellant and lived with him in Cavite.
  • Incident and Investigation
    • The Philippine National Police-Women and Children Protection Center (PNP-WCPC) received a referral from the Australian Federal Police about an online sexual exploitation case involving a Filipino suspect and a young Filipino female victim.
    • The suspect was traced to the email account ivyianl823@protonmail.com, used to arrange sexual exploitation transactions involving AAA.
    • On September 25-27, 2017, an entrapment operation was conducted. PCI Virtudazo posed as a customer communicating with the suspect, agreeing to a P20,000 fee for the minor's sexual services.
    • The accused-appellant was identified as the person behind the email and phone number used in the transaction.
    • On the day of the operation, charged with maintaining and harboring AAA for sexual exploitation, the accused was arrested at SM Megamall upon receiving P5,000 as a down payment.
  • Trial Proceedings
    • The prosecution presented multiple police officers, a foreign liaison officer, and the minor victim as witnesses.
    • AAA testified about repeated sexual exploitation by accused-appellant involving different foreigners beginning when she was about five or six years old.
    • The accused-appellant denied the charges, claiming he was accompanying AAA to visit her dead father’s grave and to meet a friend to return personal belongings.
    • Items seized from accused-appellant included marked money, a cellphone, a backpack containing sex aids, and other personal effects.
  • Lower Court Decisions
    • The Regional Trial Court (RTC) found accused-appellant guilty beyond reasonable doubt of Qualified Trafficking in Persons and sentenced him to life imprisonment, a fine, and damages to AAA.
    • The Court of Appeals (CA) affirmed the RTC decision, ruling the evidence sufficiently established all elements of the crime beyond reasonable doubt.

Issues:

  • Whether the prosecution proved beyond reasonable doubt the guilt of accused-appellant for Qualified Trafficking in Persons under Section 4(e) in relation to Section 6(a) of R.A. No. 9208, as amended.
  • Whether AAA’s minority was established by the prosecution despite lack of documentary evidence.
  • Whether accused-appellant was proven to be the person behind the email account used to arrange the trafficking transaction.
  • Whether the defense of denial and alternative explanation sufficiently raised reasonable doubt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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