Case Summary (G.R. No. L-20866)
Charges and Background
Joemarie and Amirah were charged with qualified trafficking in persons under Republic Act No. 9208, as amended by Republic Act No. 10364. The allegation states that, on April 13, 2014, they unlawfully recruited, transported, and provided the minors for forced labor, asserting that they were to work as onion peelers with an offered wage of PHP 2,500.00.
Trial Proceedings
During the trial, the prosecution presented the birth certificates and testimonies of the minor complainants. They recounted an encounter with Joemarie where he offered them work and insisted they did not need permission from their parents. They described initially being taken to a television viewing location and subsequently transported to various locations in Marawi City, ultimately ending up as domestics without any compensation.
Defense Position
Joemarie asserted that he had no involvement in illegal activities, claiming he was merely an intermediary who directed the minors to Amirah for employment. He maintained that his actions were intended to help fellow indigenous individuals seeking work.
Regional Trial Court Decision
On June 24, 2021, the Regional Trial Court convicted Joemarie Ubanon of qualified trafficking in persons and sentenced him to life imprisonment alongside a fine of PHP 2,000,000.00, with additional damages awarded to the victims. It was concluded that Joemarie exploited the minors’ vulnerabilities and deceived them into forced labor.
Court of Appeals Ruling
On August 25, 2023, the Court of Appeals affirmed the conviction but modified the sentence by removing the phrase "without eligibility for parole." The appellate court found that the prosecution sufficiently established Joemarie's participation in a conspiracy with Amirah regarding the trafficking activities.
Legal Basis for Trafficking
Under Section 3(a) of Republic Act No. 9208, the crime of trafficking involves recruitment, transportation, or harboring persons through coercion or deception, with the intent of exploitation. The law recognizes minors as particularly vulnerable, qualifying acts of trafficking if they involve individuals below 18 years of age.
Evidence and Conspiracy
The testimonies of the minor complainants, alongside Joemarie's actions, supported the finding of conspiracy as his behavior indicated a collective intention to facilitate the victims' transport for unlawful purposes. The Cou
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Facts and Background
- Joemarie Ubanon y Man-an (Joemarie) and Amirah Macadatar (Amirah) were charged with qualified trafficking in persons.
- Incident occurred on April 13, 2014, in Bukidnon, Philippines.
- Victims were three minors: AAA270934 (14 years old), BBB270934 (14 years old), and CCC270934 (15 years old).
- Joemarie approached the victims offering employment as onion peelers with monthly wage of PHP 2,500.
- Joemarie insisted on immediate departure to employer without allowing parents' permission.
- Joemarie accompanied victims to DDD's house (Amirah's daughter) and later to the bus terminal.
- Victims were transported to Iligan City and then to Marawi City, where they were made to work as unpaid domestic helpers.
- Amirah eventually turned over the victims to AAA270934's father at a police station.
- Joemarie denied accusations, claiming he merely referred the victims to Amirah and reminded them to seek parental consent.
Procedural History
- Regional Trial Court (RTC) convicted Joemarie on June 24, 2021, sentencing him to life imprisonment and a PHP 2,000,000 fine.
- RTC also imposed moral damages of PHP 200,000 and exemplary damages of PHP 100,000 to each victim, with 6% interest per annum.
- Charge against Amirah Macadatar was archived pending arrest.
- Joemarie appealed to the Court of Appeals (CA), which affirmed the conviction on August 25, 2023 but deleted the phrase "without eligibility for parole".
- Joemarie further appealed, challenging the sufficiency of evidence linking him to transporting victims for forced labor.
Issues Presented
- Whether the prosecution sufficiently proved Joemarie's guilt beyond reasonable doubt for qualified trafficking in persons.
- Whether Joemarie participated in recruiting and transporting the victims to Marawi City for the purpose of forced labor.
- Whether the penalty and damages imposed were proper and justified under the law.
Legal Framework
- Republic Act No. 9208, as amended by Republic Act No. 10364, governs trafficking in persons.
- Section 3(a) defines trafficking in persons as recru