Case Summary (G.R. No. 176830)
Investigation and Evidence
After AAA252353’s October 2014 complaint, the WCPU-CIDG and DOJ-IACAT conducted surveillance and entrapment. Confidential informant “Franklin” provided Jerrie’s email and Facebook credentials revealing exchange of lewd photos and offers to supply minors for sexual exploitation. An entrapment operation in November 2014 led to Jerrie’s arrest and rescue of CCC252353 and DDD252353. Digital forensics on seized drives confirmed lascivious images and videos.
RTC Judgment
The Regional Trial Court found Jerrie guilty beyond reasonable doubt of:
- Two counts of qualified trafficking (RA 9208 as amended)
- Three counts of rape (Articles 266-A(1)(a), 266-A(1)(b), 266-A(2) of the Revised Penal Code, as amended)
- One count of cybersex (RA 10175)
He was sentenced to life imprisonment for trafficking, reclusion perpetua for rape through intercourse, indeterminate imprisonment for rape by sexual assault and cybersex, and ordered to pay damages.
Court of Appeals Ruling
The CA affirmed the RTC’s findings and penalties, increasing fines for qualified trafficking to ₱4,000,000 and adjusting damages awards. It upheld Jerrie’s credibility findings against his claim of fabrication, noting the spontaneous, categorical testimony of AAA252353.
Issues on Appeal
Jerrie challenged (1) the victims’ credibility, (2) validity of his entrapment and arrest, (3) the courts’ rejection of his denial defense, and (4) the appropriateness of imposed penalties and damages.
Analysis of Trafficking in Persons
Under Section 3(a), RA 9208 as amended, trafficking includes recruitment for sexual exploitation by means of force, coercion, or abuse of vulnerability. AAA252353’s testimony established Jerrie’s recruitment and sustained exploitation over more than 60 days, meeting qualified trafficking elements under Section 6(h). The Supreme Court found these elements fully proven.
Analysis of Rape Charges
Three rape counts were sustained:
- Carnal knowledge by force/intimidation (Art. 266-A(1)(a))
- Intercourse while victim intoxicated (Art. 266-A(1)(b))
- Anal intercourse (Art. 266-A(2))
The Court accorded great weight to AAA252353’s straightforward, detailed recounting. Her fear and lack of alternatives in Manila explained delayed reporting.
Analysis of Cybersex Offense
Section 4(c)(1) of RA 10175 punishes knowingly operating lascivious exhibitions via computer for consideration. Evidence included live webcam shows, distribution of indecent images for payment, and digital forensic reports confirming illicit content. The Court found all cybersex elements satisfied.
Legitimacy of Entrapment
The Court distinguished entrapment from instigation. Jerrie had prior predisposition to exploit victims for profit. Operatives merely facilitated a lawful sting based on prior complaint and intelligence. His arrest was valid.
Victim’s Credibility
The Supreme Court upheld the RTC and CA’s credibility determinations. It recognized varied victim responses to trauma and reiterated that a denial defense cannot override consistent, credible testimony.
Penalties and Damages
- Qualified Traff
Case Syllabus (G.R. No. 176830)
Facts and Antecedents
- In March 2014, AAA252353 left her home province to work in Manila and was invited by Jerrie Arraz y Rodriguez to live and work in his household, ostensibly as a domestic helper.
- Over the following months in Quezon City, Jerrie used force, intimidation and the victim’s vulnerability to exploit AAA252353 for sexual purposes, including:
- Stripping her naked, photographing and live‐streaming her via webcam to foreign clients (“Gunter,” “John,” “Maurice,” “Patrick James Powell”).
- Forcing her to perform oral sex and have intercourse with himself, with his minor ward Mark, and with foreign clients in hotel rooms and bars.
- Receiving payments from foreigners through local remittance centers in exchange for AAA252353’s sexual services.
- Jerrie also brought another minor, CCC252353, into similar exploitative situations involving hotel encounters with foreigners.
- AAA252353 became pregnant during the period of abuse but was unable to escape or report the acts immediately for lack of money, shelter, and family support in Manila.
- In July 2014, Jerrie expelled both sisters; AAA252353 and her sister found new employment and, in October 2014, AAA252353 filed a complaint at Camp Crame for rape, trafficking and cyber‐exploitation.
Investigation and Entrapment Operation
- The Women and Children Protection Unit (WCPU‐CIDG) and the Department of Justice conducted surveillance, entrapment, and forensic examinations.
- Confidential informant “Franklin” provided email and Facebook credentials; investigators discovered repeated emails from Jerrie containing indecent photos of naked women.
- An undercover operation in a Makati hotel captured Jerrie boasting about supplying intoxicated minors and adult women for sex to foreign clients, offering to drug them and sharing nude photos online.
- Arresting officers seized six hard drives, three memory cards and two USB flash drives; digital forensic analysis confirmed thousands of lascivious images and videos.
Procedural History
- The six Informations filed in the Quezon City RTC charged Jerrie with: trafficking in persons (qualified), three counts of rape (various modes), and one count of cybersex under RA 10175.
- On May 24, 2017, RTC Branch 100 convicted Jerrie on all counts, imposing life imprisonment for trafficking, reclusion perpetua for two rapes, indeterminate prision correctional/major terms for the third rape and cybersex, plus fines and damages.
- On June 18, 2019, the Court of Appeals affirmed the RTC decision with modifications to the amounts of civil indemnity and damages.
- Jerrie appealed to the S