Case Summary (G.R. No. 234013)
Procedural History
Eight Informations were filed charging Valencia and Simbillo with qualified trafficking of minors under Section 4(a) in relation to Section 6(a), RA 9208 as amended, and trafficking of adult AAA. The cases were consolidated. After plea of not guilty, RTC conducted joint trial. RTC rendered partial convictions and acquittals on June 4, 2015. CA affirmed on May 17, 2017. Appellants filed appeal to the Supreme Court.
Issues Presented
- Legality of warrantless arrests made during the entrapment operation.
- Sufficiency and relevance of evidence for convictions, including acts against AAA in February 2014.
- Applicability of precise date requirement in the Informations.
Ruling of the Supreme Court
The Supreme Court dismissed the appeal and affirmed the CA Decision with modifications on damages. It held that warrantless arrests during a valid entrapment operation constitute lawful in flagrante delicto arrests under Rule 113, Section 5(a) and Article III, Section 2 of the 1987 Constitution. The corroborated testimonies of PO3 Mendoza and victim-witnesses sufficed to prove all elements of (qualified) trafficking beyond reasonable doubt. The imprecision of dates in the Information against AAA did not render the charge infirm, as Rule 110, Section 11 allows dates “as near as possible.”
Legal Reasoning
• Entrapment vs. Instigation: Entrapment is permissible where the accused’s criminal intent originates from the accused, not the officer. Ruses to capture offenders in the act are valid so long as rights are respected (Chang v. People).
• In Flagrante Delicto Arrest: Arresting officer’s presence and direct observation of the overt act satisfy Rule 113, Section 5(a) requirements. PO3 Mendoza’s testimony confirmed he was within half-meter distance during the transaction.
• Elements of (Qualified) Trafficking: Recruitment, obtaining, offering or harboring persons by coercion, deception or taking advantage of vulnerability, for the purpose of sexual exploitation (RA 9208, Secs. 3(a) and 4(a); RA 10364, Sec. 6(a)). Minority of CCC, DDD, EEE, FFF, GGG, HHH qualified the trafficking offenses.
• Corroboration Principle: Conviction may rest on the consistent, categorical testimonies of the arresting officer and victim-witnesses without requirement of further proof (People v. Ramirez).
• Date Specification: Precise date is immaterial unless it is a material ingredient; “sometime in February 2014 and subsequently thereafter” complied with Rule 110, Section 11.
Disposition and Penalties
• Criminal Case No. 14-11900 (AAA): Simbillo guilty of trafficking under
Case Syllabus (G.R. No. 234013)
Case Title and Citation
- G.R. No. 234013, June 16, 2021
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellants: Mitchelle Valencia y Dizon (aka Ate Seysey) and Joane Simbillo y Lauretti (aka Alexis)
Facts
- Between February and May 2014 in Angeles City, Pampanga, Valencia and Simbillo engaged in recruiting, obtaining, providing, offering, maintaining, and harboring persons—minors and an adult (AAA)—for prostitution and sexual exploitation.
- A BBC News flash drive identified “pimp” Valencia offering minor girls’ sexual services; police surveillance followed.
- On May 26, 2014, PO3 Erickson Mendoza and a foreign confidential asset conducted an entrapment operation:
• Valencia offered eight girls at ₱1,500 each; Simbillo did likewise with five minors.
• When the asset agreed to pay ₱15,000, the victims and Simbillo boarded the van.
• Mendoza signaled the arrest team; marked money was recovered and victims rescued. - Victims AAA, BBB, CCC, DDD, EEE, GGG, and HHH testified to deceptive recruitment, past sexual exploitation incidents, and commission deductions.
Procedural History
- Eight Informations (Crim. Case Nos. 14-11900 to 14-11907) charged defendants under Section 4(a) of RA 9208, as amended by RA 10364.
- Cases consolidated; accused pleaded not guilty; joint trial ensued.
- June 4, 2015 RTC Decision (Br. 59, Angeles City):
• Convicted Valencia and Simbillo in select counts (qualified trafficking and trafficking).
• Acquitted them in others for fai