G.R. No. 267360 - People vs. Vergel CaAas y Ganalon

Case Summary (G.R. No. 267360)

Charges and Legal Basis

CaAas faced three counts of qualified trafficking in persons under Section 4(a) in relation to Section 6(a) of Republic Act No. 9208, as amended by Republic Act No. 10364. The specifics of the charges involved recruiting, obtaining, hiring, providing, and offering AAA for sexual exploitation on three occasions—April 6, April 9, and April 16, 2016.

Path to Trial

Upon being charged, CaAas pleaded not guilty during his arraignment, leading to a pre-trial and trial on the merits. The prosecution consolidated the three cases based on the similarities of the offenses. AAA testified in detail regarding her interactions with CaAas and the circumstances that led her into situations of sexual exploitation.

Victim’s Account

AAA testified that after running away from home, she was introduced to CaAas as a potential employer who offered "work." During the incidents, CaAas provided clothing and makeup for AAA and her friend Alrose, and subsequently transported them to various locations to meet clients. Subsequently, AAA detailed her experiences of sexual exploitation, revealing that during the encounters, she was coerced into providing sexual services while under the influence of CaAas's directions.

Accused's Defense

CaAas presented a defense of denial, claiming that AAA and her friend approached him for makeup services, questioning the credibility of AAA’s testimony. He argued that Alrose recruited AAA, not him, and denied any wrongdoing. However, he acknowledged his presence during outings and interactions corroborated by the testimonies of the victim.

Trial Court’s Decision

The Regional Trial Court (RTC) convicted CaAas, finding that the prosecution established the elements of qualified trafficking beyond a reasonable doubt based on AAA's credible testimony. CaAas was sentenced to life imprisonment and a fine of PHP 2,000,000.00 for each count, along with moral and exemplary damages awarded to the victim.

Appeal Process

CaAas appealed the RTC's decision, asserting that the prosecution failed to prove the elements of the crime and that AAA’s testimony was inconsistent and unreliable. The Court of Appeals (CA), however, affirmed the RTC's decision but modified the amount of exemplary damages from the RTC ruling.

Supreme Court's Ruling

After reviewing the case, the Supreme Court upheld the conviction, asserting tha

Case Syllabus (G.R. No. 267360)

Case Background and Charges

Accused-appellant Vergel CaAas y Ganalon was charged with three counts of qualified trafficking in persons under Section 4(a) in relation to Section 6(a) of Republic Act No. 9208, as amended by Republic Act No. 10364.
The criminal cases involved three separate incidents on April 6, 9, and 16, 2016.
The victim, referred to as AAA, a 13-year-old minor at the time, was assisted by her mother, BBB.
The charges involved recruiting, transporting, offering, and exploiting AAA for prostitution and other forms of sexual exploitation.
The prosecution moved for consolidation of the three cases, which was granted.

Facts and Testimonies

AAA ran away from home and stayed at her friend Alrose's house, who introduced AAA to CaAas.
CaAas offered a "work" opportunity which was revealed to be prostitution involving sexual services for money.
On April 6, 2016, CaAas prepared AAA and Alrose with clothes and makeup, and facilitated their meeting with a client at Victoria Court, Pasay City.
AAA and Alrose rendered sexual services including sexual intercourse and oral sex to the client.
Payments were collected by CaAas and distributed to AAA and Alrose with CaAas keeping a commission.
Similar acts occurred on April 9, 2016, at Beacon Tower, and on April 16, 2016, in Imus, Cavite, involving different clients and circumstances.
AAA was not initially paid on the last occasion and was later rescued by her mother and barangay authorities.
AAA testified in detail about each incident, including CaAas's role in recruitment, transport, and receiving payments.
CaAas denied involvement in the acts, claiming Alrose recruited AAA, and denied spending time with AAA and Alrose on some dates; he admitted attending a summer outing with Alrose but claimed AAA was under influence of drugs.
CaAas also admitted paying BBB PHP 50,000 to withdraw the case.

Trial Court Proceedings and Decisions

The Regional Trial Court (RTC) found CaAas guilty beyond reasonable doubt of three counts of qualified trafficking in persons.
The RTC sentenced CaAas to life imprisonment and a fine of PHP 2,000,000 for each count.
The RTC awarded m