Case Summary (G.R. No. 260639)
Background and Criminal Charges
The accused-appellant was arraigned and entered a plea of "not guilty." The prosecution, supported by witnesses including the minor complainants and Intelligence Agents (IA), brought forth documentary evidence such as affidavits, registered marked money, and birth certificates. The fatal allegation was that the accused recruited and maintained minors for prostitution and facilitated sexual exploitation on a large scale.
Incident and Investigation Details
NBI Anti-Human Trafficking Division (AHTRAD) received information about sexual trafficking of minors in a particular shopping mall. Surveillance operations by IA Sarno and IA Natalia confirmed the accused-appellant’s involvement through his active approach to undercover agents posing as customers. He offered sexual services of minors at a price, serving effectively as their broker or “bugaw.” A formal entrapment and rescue operation was authorized, culminating in the arrest of the accused and the rescue of the minor complainants.
Defense and Trial Court Findings
The accused-appellant claimed that he was simply approached by unknown men, forced into custody, and denied knowing the complainants or involvement in any trafficking activities. The RTC, in its July 21, 2018 decision, found the accused-appellant guilty beyond reasonable doubt of Qualified Trafficking in Persons, emphasizing the credibility and consistency of victims’ testimonies, and sentenced him to life imprisonment without parole and a P2,000,000 fine.
Appellate Court Decision
On appeal, the Court of Appeals (CA) affirmed the RTC’s conviction on September 15, 2020, dismissing accused-appellant’s allegations of inconsistencies in the testimonies as minor details irrelevant to the core facts. The CA imposed the penalty of life imprisonment and a P2,000,000 fine and ordered the accused to pay each of the four victims P500,000 as moral damages and P100,000 as exemplary damages, with six percent interest per annum on monetary awards from finality until full payment.
Issues on Appeal
The central issue before the Supreme Court was whether the CA correctly affirmed the RTC’s finding that the accused-appellant was guilty beyond reasonable doubt of Qualified Trafficking in Persons.
Legal Elements of Trafficking in Persons under RA 9208, as amended
To convict for Trafficking in Persons, the prosecution must establish:
- The act of recruitment, transportation, transfer, harboring, or receipt of persons (with or without the victims’ consent);
- The means used such as threat, force, coercion, abduction, fraud, abuse of power, or giving or receiving payments to control another; and
- The purpose of exploitation, including prostitution or sexual exploitation.
Qualified Trafficking requires the commission of any of these acts (Sections 4, 4A–4C, or 5) plus the existence of qualifying circumstances under Section 6, such as the victim being a child or the crime committed on a large scale.
Application of the Law to the Case
The accused-appellant was charged specifically under Section 4 (a) and (e) for recruiting and maintaining persons for prostitution, qualified by Section 6 (c) for the large-scale nature of the crime. The court noted that when minors are involved, consent is immaterial, and the law recognizes trafficking even without the use of means enumerated in Section 3 (a).
Sufficiency of the Evidence and Identification of the Accused
The prosecution adequately proved that the accused-appellant:
- Approached undercover agents and offered minors for sexual services at P1,000 per child;
- Instructed a minor to recruit others to entertain customers;
- Imposed a system where minors remitted part of their earnings to him as commission.
The agents and victims consistently identified the accused-appellant as the pimp. The defense’s alibi and denial were unsubstantiated and weak compared to the affirmative, positive, and credible testimony of prosecution witnesses.
On the Age of the Victims and Qualifying Circumstance
The prosecution failed to sufficiently prove the minority of the victims AAA, BBB, CCC, and DDD. Certificates of live birth and authentic documents were either unavailable or contradictory. For at least two complainants, their presented birth certificates indicated ages above 18 at the time of the incident, thus negating the application of the qualifying circumstance of trafficking involving children (Section 6 (a)). However, the large-scale nature of the crime (involving four victims) sat
...continue readingCase Syllabus (G.R. No. 260639)
Background and Procedural History
- The case involves the appeal against the decision of the Court of Appeals (CA) dated September 15, 2020, which affirmed the July 21, 2018 Decision of the Regional Trial Court (RTC) of xxxxxxxxxxx, Branch 9.
- Accused-appellant XXX was found guilty beyond reasonable doubt of Qualified Trafficking in Persons under Sections 4(a) and 4(e) in relation to Sections 6(a) and 6(c) of Republic Act No. 9208 (Anti-Trafficking in Persons Act of 2003), as amended by RA 10364.
- The accused was charged with providing four minor children for the purpose of prostitution and other forms of sexual exploitation in exchange for a fee.
- The accused entered a plea of "not guilty" at arraignment and was subsequently tried based on evidentiary presentations including witness testimonies and documentary evidence.
- The prosecution presented private complainants AAA, BBB, CCC, and DDD, along with Intelligence Agents, while the defense presented the accused-appellant as the sole witness.
- Upon conviction by the RTC, the accused appealed to the CA, which affirmed the conviction with modifications including the imposition of damages to victims.
- The accused filed a Notice of Appeal to the Supreme Court, contesting the affirmation by the CA.
Facts and Evidence Presented
- On January 27, 2014, the National Bureau of Investigation (NBI) Anti-Human Trafficking Division received reports of sexual trafficking at a shopping mall.
- Surveillance revealed accused-appellant approached agents in civilian clothes offering sexual services of minors at a fee of P1,000.
- An entrapment and rescue operation was conducted on January 28, 2014, with poseur customers paying for sexual services, leading to the arrest of accused-appellant.
- The victims and agents testified that accused-appellant acted as a "bugaw" or pimp by finding paying customers and receiving a commission from the fees.
- Documentary evidence included affidavits, birth certificates, marked money, and official reports which corroborated the testimonies.
- The accused’s defense was that he was shopping alone and was forcibly taken to the NBI office after an invitation to eat with two men, denying knowledge or involvement in the charges.
Legal Issues
- Whether the Court of Appeals correctly affirmed the RTC’s conviction of accused-appellant for Qualified Trafficking in Persons under Sections 4(a) and (e) in relation to Sections 6(a) and (c) of RA 9208, as amended.
- Whether the prosecution proved beyond reasonable doubt the elements of Qualified Trafficking in Persons and the identity of the accused as perpetrator.
- Whether the qualifying circumstance of the victims being minors was sufficiently established.
- The credibility and sufficiency of evidence supporting the conviction, including the testimonies and documentary proofs presented.
- The appropriateness of the penalties and damages awarded by the trial and appellate courts.
Elements of Qualified Trafficking in Persons
- The crime requires proof of:
- Acts such as recruitment, obtaining, hiring, providing, offering, transporting, transferring, maintaining, harboring, or receiving persons by any means.
- The purpose being prostitution, pornography, or sexual exploitation.
- The e