G.R. No. 273190 - People vs. XXX

Informations were filed against the accused-appellant, XXX, for violations of Section 4(a), in relation to Section 6(a) of Republic Act No. 9208 (Anti-Trafficking in Persons Act) and Sections 5(b) and 10(a) of Republic Act No. 7610 (Special Protection of Children Against Abuse, Exploitation and Discrimination).
Four criminal cases were consolidated for joint trial: Criminal Case Nos. FC-13-1155 to FC-13-1158.
The charges stemmed from acts involving AAA, a 15-year-old minor (identity protected), who was allegedly trafficked, exploited, and abused by XXX.

Qualified trafficking in persons for recruiting, transporting, transferring, harboring, and employing AAA for sexual exploitation, specifically prostitution, with the qualified circumstance of AAA's minority (15 years old).
Acts of child abuse, cruelty, and exploitation committed on AAA involving physical harm for refusal to have sexual intercourse (throwing objects, pulling hair).
Additional acts of physical abuse (kicking causing a fall and injury), and inducing AAA to engage in sexual intercourse by forcing her to take shabu (a dangerous drug) to facilitate sexual acts.

XXX pleaded not guilty to all charges during arraignment.
The parties stipulated on XXX's identity, AAA's minority, and their meeting at a location in 2007.
Prosecution witnesses included AAA (victim), BBB (co-worker of AAA), and Lea Daet (DSWD official).
The defense rested on the testimony of XXX alone.

AAA was initially a house helper but ordered by Margie to work in a videoke bar entertaining male customers, where proceeds went to Margie.
In August 2010, AAA met XXX at the port; thereafter, XXX transported her to various locations where she was employed as a Guest Relations Officer engaging in sexual favors for money.
AAA was pimped to male clients, with payments divided among XXX, Margie, and Ann (bar owner).
AAA's salary was withheld ostensibly to cover board, lodging, clothing, and food, leaving her with minimal earnings.
XXX physically abused AAA and forced drug use to facilitate sexual acts.
AAA was rescued during a CIDG raid following a tip-off by BBB.

XXX denied involvement in prostituting AAA or knowledge of her sexual activities.
XXX met AAA while operating a tricycle, claiming AAA told him she was 19 years old.
XXX testified they had a romantic relationship; he only knew AAA worked as a waitress.
XXX was shocked upon learning AAA’s true age and work after the CIDG raid.
He attempted to support AAA and maintain a relationship, which ended when AAA accused him of infidelity.

Convicted XXX of qualified trafficking in persons under RA 9208 but acquitted him of violations under RA 7610 due to lack of corroborative evidence and delayed reporting by AAA.
Ordered payment of civil, moral, and exemplary damages to AAA.
Sentenced XXX to life imprisonment and a P2,000,000 fine for qualified trafficking.

Affirmed the trial court's findings on qualified trafficking.
Credited AAA's testimony and corroboration by BBB, including proof of AAA’s minority.
Denied XXX's appeal and upheld the life imprisonment sentence and damages awarded.

XXX contested the sufficiency of evidence, inconsistencies in AAA's testimony and affidavits, and proof of AAA's minority.

Whether the prosecution sufficiently proved the elements of qualified trafficking in persons under Section 4(a), in relation to Section 6(a) of Republic Act No. 9208 against XXX.
Whether AAA's minority was proven beyond reasonable doubt.
Whether inconsistencies and delayed reporting by the victim affect the credibility and sufficiency of prosecution evidence.