Case Summary (G.R. No. 141011)
Charges and Proceedings
Accused-appellant XXX was charged on October 18, 2016, with Qualified Trafficking in Persons for maintaining and harboring AAA, a minor, by offering and peddling her for monetary consideration in exchange for sexual services, constituting sexual exploitation and prostitution of a child, which is contrary to law. The accused pleaded not guilty, and trial ensued with testimony from police officers, the victim, an Australian Federal Police liaison, and the accused himself.
Prosecution’s Evidence and Investigation
Evidence showed that an international investigation initiated by the Australian Federal Police revealed an online trafficking operation involving a Filipino suspect identified through the email address ivyian1823@protonmail.com. The Philippine National Police-Women and Children Protection Center (PNP-WCPC) undertook an undercover operation with PCI Virtudazo posing as a customer. Communications with the suspect confirmed the offer of a 10-year-old girl for sexual services at a price initially set at Php 30,000 and later reduced to Php 20,000.
Entrapment Operation and Arrest
An entrapment was conducted at SM Megamall’s J.CO Donuts Cafe on September 27, 2017, where accused-appellant met with supposed customers, introduced AAA as the person offered for sex, and accepted Php 5,000 as a down payment. The team then arrested accused-appellant based on the pre-arranged signal and presented evidence such as marked money, a cellphone, and items indicative of sexual exploitation. The minor victim was immediately taken into protective custody.
Victim’s Testimony
AAA testified that she was coerced by her uncle to perform sexual acts including oral sex on foreigners as well as on the accused himself, under threats and promises of discipline that instilled fear and obedience. She confirmed details of the transaction and the arrest, recounting her experiences from a young age, highlighting the abuse and exploitation she endured.
Defense’s Version
Accused-appellant denied the charges, claiming the backpack and items found were not his and that the meeting at SM Megamall was to return personal belongings to an acquaintance named Asian Lover, connected to an online personality JORDY59. He asserted ignorance of the alleged sexual exploitation, claiming he was merely seeking to retrieve lost items, and that the incriminating words heard were misunderstood or misinterpreted.
Regional Trial Court’s Decision
The RTC found the accused guilty beyond reasonable doubt of Qualified Trafficking in Persons, emphasizing the credibility of prosecution witnesses, especially the victim, and the regularity of police procedures during the investigation and entrapment. The accused’s denial was deemed self-serving, inconsistent, and uncorroborated. The court sentenced him to life imprisonment, a fine of Php 2,000,000, and ordered damages for the victim.
Court of Appeals’ Affirmation
The CA affirmed the RTC’s decision, citing that all elements of trafficking were sufficiently proven: the act of recruitment and harboring; the means of coercion and taking advantage of vulnerability; and the purpose of sexual exploitation. It especially noted the qualified nature of the offense due to the victim’s minority. The CA found the testimony of the victim and the police as credible and well-substantiated, rejecting the accused’s defense for lack of evidence.
Issues on Appeal
The accused-appellant argued on appeal that the prosecution failed to prove the victim’s minority by documentary evidence and to sufficiently establish that he was the person behind the incriminating email account. He contended this in an attempt to undermine the qualified nature of the offense and the identity of the perpetrator.
Supreme Court Ruling on the Appeal
The Supreme Court ruled that the appeal was without merit. It held that:
- The prosecution sufficiently proved the elements of trafficking, including the recruitment, coercion, and purpose of sexual exploitation.
- The victim’s minority was established through parties’ stipulation and the accused’s own admission.
- Even absent documentary proof, the victim’s credible and detailed testimony demonstrating coercion satisfied the requirements to prove qualified trafficking, where consent of a minor is irrelevant by law.
- The accused-appellant was correctly identified as the person controlling the email account, as he communicated and arranged the meeting under the said account, accepted marked money, and introduc
Case Syllabus (G.R. No. 141011)
Background and Procedural Posture
- The accused-appellant, XXX, was charged with Qualified Trafficking in Persons under Section 4(e) in relation to Section 6(a) of Republic Act No. 9208 (Anti-Trafficking in Persons Act of 2003), as expanded by Republic Act No. 10364 (Expanded Anti-Trafficking in Persons Act of 2012).
- Charges stemmed from acts allegedly committed from September 25 to 27, 2017, in Metro Manila, wherein accused-appellant unlawfully maintained and harbored a 10-year-old minor, AAA, offering and peddling her for sexual services to a male customer for monetary consideration.
- Accused-appellant pleaded not guilty during arraignment.
- The case was tried before the Regional Trial Court (RTC) which found accused-appellant guilty beyond reasonable doubt.
- The Court of Appeals (CA) affirmed the RTC's decision on October 15, 2019.
- The present appeal constitutes accused-appellant’s final resort seeking to overturn his conviction.
Factual and Evidentiary Findings of the Prosecution
- Investigation was triggered by a referral from the Australian Federal Police (AFP) to the Philippine National Police-Women and Children Protection Center (PNP-WCPC) concerning online sexual exploitation of a Filipino minor.
- Intelligence linked an online personality “JORDY59” to the trafficking and exploitation of minors via the Darknet, a hidden internet network trading child pornographic materials.
- The PNP-WCPC's PCI Michael T. Virtudazo undertook an undercover operation communicating with an email account ivyian1823@protonmail.com, allegedly controlled by the trafficker.
- During the correspondence, the accused offered "his daughter," identified later as AAA (his niece), for sexual services at a price initially P30,000.00, later reduced to P20,000.00.
- An entrapment operation was conducted at J.CO Donuts Cafe, SM Megamall, involving the placing of marked money as consideration and physical identification of accused-appellant wearing the described attire.
- PO2 Mary Grace A. Guache acted as the foreigner’s companion undercover and directly negotiated with accused-appellant, who admitted AAA could perform sexual acts such as "handjob," "blowjob," and intercourse.
- Accused-appellant was arrested upon a prearranged signal; marked bills and other items related to sexual exploitation were seized.
- The minor AAA testified in detail about her forced sexual exploitation by accused-appellant, who is her paternal uncle.
- Other prosecution witnesses, including police officers and the Australian federal officer, supported the operation's procedural regularity and the chain of evidence.
- Videographic evidence presented depicted AAA engaged in sexual acts, confirming abuse consistent with testimonies.
Defense’s Version and Claims
- Accused-appellant denied the allegations, asserting his intent was to visit his deceased brother’s grave with AAA.
- Claimed he stopped at SM Megamall merely to meet an online friend, “Asian Lover,” to exchange items mistakenly swapped involving JORDY59.
- Argued that the brown envelope containing P5,000.00 handed by PO2 Guache was misunderstood as containing his personal belongings.
- Denied ownership of sex-related items seized from the backpack, claiming the bag belonged to JORDY59.
- Denied knowled