Case Summary (G.R. No. 258194)
Facts of the Case
The accused-appellant was charged in eight separate Informations spanning various counts related to child prostitution and trafficking of minors. Reports indicate that from December 31, 2016, to January 11, 2017, XXX acted as a procurer and exploited AAA for sexual favors in exchange for monetary compensation. The specifics of the multiple encounters involved coercion, manipulation, and the clear vulnerability of the minor involved.
Prosecution's Version
The prosecution supported its claims through testimonies from multiple witnesses, including the father of the complainant and various officials from the Department of Social Welfare and Development. The complainant recounted how she was approached by the accused while seeking refuge and how she was subsequently exploited through a series of sexual transactions. Physical examinations corroborated the testimony, revealing injuries consistent with sexual abuse.
Defense's Version
The defense rested its case solely on the accused's denial of the allegations. XXX contended that he had only met the complainant shortly before her disappearance and claimed ignorance of her circumstances. Crime lab results and the social background of the accused were also presented, but they did not absolve him of the charges.
Ruling of the Regional Trial Court
The RTC found XXX guilty beyond a reasonable doubt on multiple counts of child exploitation and trafficking. It sentenced him to various prison terms depending on the count, awarding monetary reparations to the complainant. The court highlighted the coherent and consistent testimony of the complainant as pivotal in establishing the accused's guilt, despite his alibi and defense arguments.
Appeal to the Court of Appeals
Following the RTC's ruling, XXX appealed to the CA, raising issues of inconsistencies in the complainant's testimony that he claimed created reasonable doubt. However, the appellate court emphasized the need for a comprehensive assessment of witness credibility, noting the trial court's firsthand observation during testimonies.
Ruling of the Court of Appeals
The CA upheld most of the RTC's findings and sentences, but made modifications regarding some of the penalties. The appellate court ruled that all elements of the crimes charged were sufficiently proven, and the trial court's conclusions regarding credibility and the minor's exploitation were affirmed.
Supreme Court's Ruling
Upon further appeal, the Supreme Court found that the guilt
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Parties and Procedural History
- Plaintiff-Appellee: People of the Philippines
- Accused-Appellant: XXX (name withheld for privacy and confidentiality pursuant to R.A. 7610 and Supreme Court rules)
- The Court of Appeals' Decision in CA-G.R. CR-HC No. 12128 affirmed the Regional Trial Court's (RTC) Judgment with modifications.
- RTC presided over Criminal Case Nos. 2017-0198 to 2017-0203, 2017-0199, and 2017-0685 to 0686 involving various charges under R.A. 7610 and R.A. 9208.
Charges Against the Accused-Appellant
- Two counts of violation of Section 5(b) of R.A. 7610 (Special Protection of Children Against Abuse, Exploitation, and Discrimination Act) involving sexual intercourse with a child exploited in prostitution or other sexual abuse.
- Three counts of violation of Section 5(a)(1) of R.A. 7610 for acting as a procurer of a child prostitute.
- Three counts of violation of Section 4(a) in relation to Sections 6(a) and 10(c) of R.A. 9208 (Anti-Trafficking in Persons Act of 2003, as amended by R.A. 10364) for recruiting a child for sexual exploitation.
Factual Background
- The victim is a 13-year-old minor identified as AAA, born October 26, 2003.
- On December 31, 2016, AAA left her home due to family issues and encountered accused-appellant, who offered her accommodation and acted as procurer for sexual services.
- Accused-appellant facilitated and promoted AAA's child prostitution by offering her to three male clients on separate dates for monetary consideration.
- Incidents include sexual intercourse forced by accused-appellant against AAA's will and recruitment for prostitution.
- Physical examination by City Health Officer showed healed hymenal lacerations, cervical secretions, and positive gonococcal infection, corroborating complainant's testimony.
Version of the Prosecution
- Presented testimonies of victim AAA, her father, DSWD representative, NBI agent, and City Health Officer.
- Details include: accused-appellant's use of coercion, intimidation, and recruitment of AAA to engage in prostitution.
- Specific transactions where accused-appellant received commission from payments made to the victim by male clients.
- Evidence of sexual intercourse without consent on January 3 and 5, 2017.
- Victim's confession to NBI that accused-appellant was keeping her for prostitution.
Version of the Defense
- Accused-appellant testified to first meeting victim on January 15, 2017, introduced by a friend.
- Denies any involvement in sexual abuse or acting as procurer.
- Claims victim stayed with him voluntarily and denies being "XXX" named in the complaints.
- Arrested forcibly by police without prior knowledge or consent.
Trial Court Decision
- On October 26, 2018, RTC found a