Case Summary (G.R. No. 78090)
Applicable Law
The governing law is Republic Act No. 9208, known as the Anti-Trafficking in Persons Act of 2003. Section 4(a) of the Act establishes unlawful acts related to recruitment and exploitation, particularly when involving minors, as qualified trafficking in persons.
Background of Charges
XXX was charged with two counts of Qualified Trafficking in Persons under Criminal Case Nos. 2013-0202 and 2013-0203. The first charge involved AAA, who was 14 years old at the time, while the second charge involved CCC, who was 15 years old. Both were recruited under deceitful pretenses to work in a bar for sexual exploitation.
Trial Proceedings
During arraignment, XXX pleaded not guilty. The pre-trial established certain facts, including the minors’ identities and XXX's ownership of the establishment where the unlawful acts occurred. The prosecution presented evidence detailing how the victims were lured into prostitution under the guise of being waitresses.
Evidence Presented by Prosecution
The prosecution narrated that three minors, including AAA, were recruited through XXX, who instructed them to claim they were 18 years old to deceive customers. The minors were subjected to sexual acts and shared their earnings with XXX. The prosecution's evidence was supported by testimonies from AAA and other minors, detailing their exploitation and the coercive conditions they faced.
Defense's Position
XXX’s defense argued that AAA's testimony was inconsistent and lacked credibility, asserting that the prosecution failed to prove AAA’s minority and the wrongful nature of XXX’s activities. The defense contended that AAA's actions after her initial escape undermined her credibility and conflicted with typical human behavior.
RTC Judgment
The RTC convicted XXX in Criminal Case No. 2013-0202 for violating Section 4(a) of RA 9208, finding sufficient evidentiary support for the charge against AAA. However, XXX was acquitted in Criminal Case No. 2013-0203 for insufficient evidence concerning CCC.
CA Ruling
The CA upheld the RTC's judgment, affirming the conviction with modifications to the damages awarded to AAA. The appellate court emphasized that the prosecution established all elements of the crime of Qualified Trafficking in Persons, which included recruitment and coercion of minors for sexual exploitation, as laid out in RA 9208.
Key Findings and Conclusions
The
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Case Overview
- This case concerns the appeal of XXX, the accused-appellant, challenging the decision of the Court of Appeals dated July 20, 2017.
- The Court of Appeals affirmed the Regional Trial Court's judgment which found XXX guilty beyond reasonable doubt of violating Section 4(a) in relation to Sections 6 and 10 of Republic Act No. 9208, known as the Anti-Trafficking in Persons Act of 2003.
- The accused was sentenced to life imprisonment and ordered to pay various damages to the complainant, AAA (also known as BBB).
Facts of the Case
- XXX was charged with two counts of Qualified Trafficking in Persons, specifically for recruiting, harboring, and compelling minors AAA and CCC to work as waitresses and guest relation officers for sexual exploitation.
- AAA was 14 years old, and CCC was 15 years old at the time of the offenses.
- The prosecution presented evidence detailing how AAA and her friends were recruited under false pretenses, claiming they would work as waitresses, but were instead forced into prostitution.
Evidence for the Prosecution
- On September 28, 2012, AAA was approached by GGG (her friend’s mother) and offered work as a waitress in a bar.
- XXX, identified as "Mama Diane," misled AAA and her friends regarding the nature of their employment, instructing them to lie about their ages.
- The minors were taken to a bar where they were forced to entertain male customers and engage in sexual activities for monetary compensation, which was collected by XXX.
- AAA testified that she and her friends were not paid sala