Title
People vs. Casio
Case
G.R. No. 211465
Decision Date
Dec 3, 2014
Shirley Casio convicted for trafficking minors in Cebu City; entrapment valid, minors' consent irrelevant, life imprisonment imposed.

Case Summary (G.R. No. 211465)

Petitioner and Respondent

• Petitioner: People of the Philippines (Plaintiff-Appellee in lower courts)
• Respondent: Shirley A. Casio (Accused-Appellant)

Key Dates

• May 2–3, 2008: Commission of the offense in Cebu City
• May 5, 2008: Filing of the information charging Qualified Trafficking in Persons
• August 10, 2010: RTC conviction (20 years, ₱1 million fine)
• June 27, 2013: CA decision (life imprisonment, ₱2 million fine, moral damages)
• December 3, 2014: Resolution by the Supreme Court

Applicable Law

• 1987 Philippine Constitution (as case decided after 1990)
• Republic Act No. 9208 (Anti-Trafficking in Persons Act of 2003), Section 4(a) qualified by Section 6(a)
• Republic Act No. 4103 (Indeterminate Sentence Law), as modified by RA 9346 (no parole for reclusion perpetua)

Material Facts

  1. IJM coordinated a buy-bust style entrapment to rescue minors from trafficking in Cebu City’s red-light district.
  2. Decoys PO1 Luardo and PO1 Veloso, acting as tour guides, used marked money and radio communications to effectuate the operation.
  3. Accused approached decoys with “Chicks mo dong?” (“Do you like girls?”), then fetched AAA (17 years old) and BBB.
  4. She negotiated a P500 fee, received marked money in Room 24 of Queensland Motel, and was immediately arrested.
  5. AAA and BBB were placed under IJM and DSWD custody; AAA testified to prior prostitution under another pimp.

Trial Court Proceedings and Findings

• RTC found all elements of Section 4(a), qualified by Section 6(a) RA 9208, proven beyond reasonable doubt:
– Act: Recruitment and receipt of minors for prostitution
– Means: Financial transaction and inducement
– Purpose: Sexual exploitation
• Held that consummation occurs upon solicitation and receipt of money, not actual intercourse.
• Sentence: 20 years’ reclusion and ₱1 million fine; costs of proceedings.

Court of Appeals Ruling

• Affirmed guilt, modified penalty to reclusion perpetua and ₱2 million fine.
• Awarded each private complainant ₱150,000 moral damages.
• Denied appeal.

Issues on Appeal

  1. Validity of entrapment without prior surveillance or knowledge of the subject and victims.
  2. Sufficiency of evidence regarding accused’s predisposition and history in trafficking.
  3. Appropriateness of trafficking conviction despite victim’s admission of prostitution.

Entrapment Doctrine

• Philippine jurisprudence applies both objective (police conduct) and subjective (predisposition) tests.
• Accused initiated the transaction by soliciting decoys, demonstrating predisposition to commit the offense.
• No undue or illicit inducement by police; marked money and procedural safeguards (Miranda warning) were observed.
• Prior surveillance is not a prerequisite; flexibility in operations is upheld so long as rights are unviolated.

Legal Analysis and Findings

• Elements of qualified trafficking in persons under RA 9208:

  1. Recruitment, transportation, or receipt of persons (minors)
  2. By means of monetary inducement
  3. For the purpose of sexual exploitation (prostitution)
    • Knowledge or consent of a minor is immaterial under Section 3(a): consent is rendered irrelevant.
    • Victim’s age (17) triggers qualification under Section 6(a) (trafficked person is a child).
    • Evidence, including direct testimony and documentary proof (birth certificate), established all elements.

Penalt




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