Case Summary (G.R. No. 235652)
Factual Background
From 2008 until March 5, 2011, XXX and YYY compelled their children to engage in cybersex performances via webcam. AAA, then age 13 to 14, was ordered to perform simulated sexual acts and expose intimate body parts to paying online viewers. BBB (age 10) and CCC (age 9) were required to dance naked on camera for a foreign client known as “Sam.” The children were led to believe that earnings were necessary for the family’s daily sustenance. In April 2010, XXX allegedly transported AAA to Makati City and delivered her to John Hubbard for prostitution in exchange for ₱100,000.
Procedural History
· February 2011: AAA sought assistance from the DSWD and NBI, leading to a rescue operation, seizure of computers, and arrest of XXX and YYY.
· October 23, 2015 (RTC): Convicted XXX and YYY for four counts of Qualified Trafficking in Persons; sentenced to life imprisonment, ₱2,000,000 fine per count, ₱30,000 moral and ₱10,000 exemplary damages each.
· August 25, 2017 (CA): Affirmed convictions, reduced YYY’s liability to three counts, increased damages to ₱500,000 moral and ₱100,000 exemplary per count.
· September 2017: Accused-Appellants filed a timely appeal to the Supreme Court.
Issue Presented
Whether XXX and YYY are guilty beyond reasonable doubt of Qualified Trafficking in Persons for three counts (YYY) and four counts (XXX) under Sections 4(a), 4(e) in relation to Sections 6(a) and 6(d) of RA 9208.
Applicable Legal Framework
Trafficking in Persons (Section 3[a], RA 9208): Recruitment, transportation, transfer, harboring or receipt of persons for exploitation.
Qualified Trafficking (Section 6): Elevated penalty when (a) the victim is a child; (d) the offender is a parent or exercises authority over the victim.
Acts Prohibited (Section 4):
• 4(a) – recruit, transport, provide or receive persons for prostitution or sexual exploitation;
• 4(e) – maintain or hire a person for prostitution or pornography.
Supreme Court’s Analysis
- Parental Authority & Vulnerability: XXX and YYY, as biological parents, exercised control over the minors and exploited their vulnerability.
- Elements Proven Beyond Reasonable Doubt:
− Relationship: Established parent-child bonds.
− Act: Children performed sexualized acts on webcam and in person.
− Compensation: Parents received payment for each performance.
− Means: Deception and abuse of power to convince minors of necessity for family support. - Credibility of Witnesses: The trial court properly credited the straightforward testimonies of AAA, BBB, and CCC, with no evident collusion or ill motive.
- Count Allocation: YYY was charged in only three of the four Informations; thus his liability was confined to those three counts.
- Transportation Charge: XXX alone was charged under Section 4(a) for transporting AAA to Makati for prostitution with John Hubbard.
Penalties and Damages
Under Section 10
Case Syllabus (G.R. No. 235652)
Parties and Procedural Posture
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellants: XXX (mother) and YYY (father)
- Originating court: Regional Trial Court, Biñan, Laguna, Branch 25
- RTC Criminal Case Nos.: 21802-B, 21803-B, 21804-B, 24608-B
- CA docket: CA-G.R. CR-H.C. No. 08446; Decision dated August 25, 2017
- SC docket: G.R. No. 235652; Decision dated July 9, 2018
Facts of the Case
- AAA (born December 14, 1996) was 14 years old when, from 2008 to March 5, 2011, her biological parents conspired to maintain and exploit her for cyber-prostitution and pornography via computer, webcam and internet
- BBB (born May 14, 2000) was 10 years old when, from 2010 to March 5, 2011, her parents forced her to dance naked on webcam for a foreign client named “Sam”
- CCC (born July 24, 2001) was 9 years old when, from 2010 to March 5, 2011, her parents similarly induced her to perform lewd acts on webcam for “Sam”
- In April 2010, XXX brought AAA to a Makati hotel to meet and be sexually exploited by a foreigner, John Hubbard, for ₱100,000
- The children testified that YYY collected and remitted the proceeds for household expenses
- In February 2011, AAA sought help from DSWD, leading to NBI investigation, execution of a search warrant, rescue of the three children, confiscation of computers, and arrest of XXX and YYY
Charges and Informations
- Four separate Informations under RA 9208 (Anti-Trafficking in Persons Act of 2003):
- Criminal Case No. 21802-B, 21803-B, 21804-B: Section 4(e) in relation to Section 6(a) and (d)—maintaining minors for prostitution and pornography
- Criminal Case No. 24608-B: Se