Case Summary (G.R. No. 152537)
Criminal Charges and Proceedings
Saldivar was charged with violating Section 4(a), qualified by Section 6(a) of Republic Act No. 9208, as amended by Republic Act No. 10364. The charge arose from accusations that she took custody of AAA266754, a 14-year-old street child, and recruited her for the purpose of prostitution and sexual exploitation.
Facts of the Case
AAA266754, after running away from home, became homeless and was introduced to Saldivar, who subsequently took her in. It was reported that Saldivar would introduce AAA266754 to male customers for sex, profiting from such acts. The abuse continued for an extended period until the victim was rescued by social services.
Defense Strategy
In her defense, Saldivar claimed that AAA266754 voluntarily chose to engage in prostitution and that she was merely facilitating connections between AAA266754 and interested parties. Saldivar alleged that the witness had a vendetta against her, claiming fabrications attributed to a social welfare officer motivated by prior complaints against her.
Findings and Trial Court Ruling
The Regional Trial Court (RTC) found Saldivar guilty based on the credible testimony of AAA266754, coupled with medical evidence indicating signs of sexual abuse. The court ruled that because AAA266754 was a minor, Saldivar's actions constituted qualified trafficking in persons, resulting in a sentence of life imprisonment and significant financial penalties, including moral damages to the victim.
Appeal to the Court of Appeals
Saldivar appealed the RTC’s decision, disputing the credibility of AAA266754’s testimony on several grounds, including inconsistencies regarding the setting of the alleged prostitution and the nature of the interactions with customers. However, the Court of Appeals (CA) upheld the RTC's conviction, noting that all essential elements of trafficking in persons were satisfied based on the testimony and corroborative evidence presented.
Supreme Court Ruling
The Supreme Court found that the prosecution had convincingly established the elements of qualified trafficking in persons as defined by Republic Act No. 9208, thereby affirming both the guilty verdict and the penalties imposed by the lower courts. The Court
...continue readingCase Syllabus (G.R. No. 152537)
Background and Procedural History
- The case involves Marivic Saldivar y Regatcho who was charged with violation of Section 4(a), qualified by Section 6(a) of Republic Act No. 9208 as amended by RA 10364 and RA 11862.
- The charges stem from allegations filed against Saldivar for recruiting, harboring, and prostitution of a minor, AAA266754, a 14-year-old street child.
- Upon arraignment, Saldivar pleaded not guilty.
- Trial followed after pre-trial, with the Regional Trial Court (RTC) convicting Saldivar.
- The Court of Appeals (CA) affirmed the RTC decision but modified the award of moral damages.
- Saldivar filed an appeal to the Supreme Court contesting the conviction.
Facts of the Case
- AAA266754, a 14-year-old minor and street child, was recruited by Saldivar for prostitution.
- AAA266754 became vagrant after running away from home and was introduced to Saldivar by a friend.
- Saldivar reportedly pimped AAA266754 to men who also bought drugs from her.
- AAA266754 testified that Saldivar received money from men before she was sexually abused and forced into prostitution.
- Social Welfare Officer Genesis M. Panganiban interviewed Saldivar who admitted sometimes directing men to AAA266754 but claimed the minor decided to accept or reject offers.
- Medical examination confirmed trauma consistent with sexual abuse.
Accused's Defense
- Saldivar denied unlawfully recruiting AAA266754 and claimed the minor voluntarily engaged in prostitution.
- She argued the minor volunteered during offers by male friends seeking paid sexual acts.
- Alleged that AAA266754 was angry at her due to police interventions affecting their living conditions.
- Accused pointed to prior complaints filed by a social welfare officer as motive for fabricating the case.
- Claimed social workers held prejudice and intended to teach her a lesson.
Trial Court Findings and Decision
- RTC found the testimony of AAA266754 credible, straightforward, and trustworthy.