G.R. No. 213760 - Santiago, Jr. y Santos vs. People

Reynaldo Santiago, Jr. y Santos, along with two co-accused, was charged with acts of trafficking in persons under Republic Act No. 9208 (Anti-Trafficking in Persons Act of 2003).
The alleged offense occurred on or about September 30, 2011 in Manila, where Santiago was accused of recruiting and offering a minor (identified as AAA) for sexual exploitation in exchange for a fee.
The Information originally charged Santiago under Section 4(c) in relation to Section 6(c) of RA 9208, but the allegations sufficiently described an act amounting to trafficking under Section 4(a).

On September 26–27, 2011, TV5 reporter Melvin Espenida and his crew, investigating prostitution operations in Plaza Morga and Plaza Moriones, coordinated with the police.
A confidential asset (alias “Romeo David”) was designated to pose as a customer. His covert microphone captured the transaction where the accused allegedly negotiated for the minor’s sexual services in exchange for a fee.
On September 29, 2011, following the complaint filed by Espenida, police operatives conducted an entrapment operation that led to the apprehension of the accused in Plaza Morga.

The police arrested Santiago along with other suspected pimps after their entrapment operation, with AAA later taken into custody and providing testimony.
AAA testified that Santiago called her, offered to pay her a portion of the fee (P350 out of P500), and led her to a nearby hotel where the transaction was to occur before the police intervened.
The testimonies of several police officers who coordinated the operation corroborated the sequence of events, including the identification of Santiago as the person who facilitated the transaction.
Santiago testified in his defense, claiming that he had merely interacted with AAA after she approached him, asserting that he did not participate in a deliberate act of trafficking.

At trial, the Regional Trial Court (Branch 42, Manila) convicted Santiago for trafficking in persons under Section 4(a) of RA 9208, based primarily on AAA’s testimony and the corroborative evidence from the police.
Santiago was sentenced to twenty (20) years imprisonment, ordered to pay a fine of One Million Pesos (P1,000,000.00), while co-accused Castillo and Legazpi were acquitted for insufficient evidence.
The Court of Appeals, in its May 30, 2013 Decision, affirmed with modifications the RTC’s conviction of Santiago, holding that all elements of qualified trafficking in persons had been established.
Santiago’s subsequent Motion for Reconsideration and the July 31, 2014 Resolution by the Court of Appeals were both denied.

Santiago filed a Petition for Review on Certiorari challenging the lower court decisions and raised issues pertaining to the sufficiency of evidence—specifically the absence of testimony from the confidential informant, Romeo David.
The Supreme Court granted procedural extensions for filing comments and allowed the submission of memoranda, eventually receiving arguments from both parties.
The central controversy was whether the evidence, predominantly AAA’s testimony supported by police corroboration, was sufficient to sustain a conviction absent the confidential informant’s testimony.

Whether AAA’s testimony, corroborated by the police entrapment operation, was sufficient to establish the elements of the crime of trafficking in persons, in the absence of the confidential informant’s direct testimony.
Whether the lack of testimony by the confidential asset “Romeo David” created reasonable doubt about Santiago’s role in facilitating the trafficking.

Whether Santiago was properly charged and convicted under Section 4(a) of RA 9208, given that the Information originally mentioned Section 4(c) but the factual allegations were more consistent with trafficking as defined under Section 4(a).

Whether the trial court had properly assessed the credibility of the testimonies of the victim (AAA) and the police officers, and whether such assessments should be afforded deference notwithstanding the absence of certain witness testimony (i.e., that of the confidential informant).