G.R. No. 252353 . July 06, 2022.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. JERRIE ARRAZ Y RODRIGUEZ, ACCUSED-APPELLANT.

FACTS

The accused-appellant, Jerrie Arraz y Rodriguez, was charged with Qualified Trafficking in Persons under RA 9208 (as amended), three counts of Rape under RA 8353, and violation of the Cybercrime Prevention Act of 2012 (RA 10175). The charges stemmed from allegations that from March to June 2014 in Quezon City, Arraz recruited, harbored, and exploited the victim, AAA, for sexual purposes. The prosecution alleged he used force, intimidation, and coercion, taking advantage of AAA’s vulnerability. He allegedly advertised her online, forced her to perform live nude shows via webcam for foreign clients, and compelled her to engage in sexual intercourse for online viewing. The rape charges involved specific instances where Arraz had carnal knowledge of AAA through force and intimidation, including while she was intoxicated, through anal penetration, and despite knowledge of her pregnancy.
The Regional Trial Court convicted Arraz on all counts. On appeal, the Court of Appeals affirmed the convictions. Arraz then appealed to the Supreme Court, arguing the prosecution failed to prove his guilt beyond reasonable doubt, specifically contesting the credibility of AAA’s testimony and the sufficiency of evidence for the cybercrime charge. He claimed the acts were consensual and part of a romantic relationship.

ISSUE

The core issue is whether the Court of Appeals erred in affirming the conviction of Jerrie Arraz for Qualified Trafficking in Persons, Rape, and violation of the Cybercrime Prevention Act of 2012.

RULING

The Supreme Court denied the appeal and affirmed the convictions. On the trafficking charges, the Court held that all elements of Qualified Trafficking were proven. The acts of recruiting and maintaining AAA for sexual exploitation through online advertisement and live shows, facilitated by coercion and abuse of vulnerability, constitute trafficking. The qualifying circumstance of the crime being committed over more than sixty days was also established by the timeframe alleged in the informations and proven by testimony. For the rape charges, the Court found AAA’s testimony credible, consistent, and convincing. Her detailed account of being forced, threatened, and intimidated into sexual acts, including while semi-conscious and despite her pregnancy, satisfied the elements of rape through force, threat, or intimidation and under circumstances where the victim was deprived of reason. The defense of consensual relationship was rejected as untenable against the clear evidence of coercion.
Regarding the cybercrime violation, the Court ruled that the elements of cybersex under Section 4(c)(1) of RA 10175 were present. Arraz willfully maintained and controlled the lascivious exhibition of AAA’s sexual organs and sexual activity via a computer system (webcam and internet) for favor or consideration from foreign clients. His active role in directing the shows and interacting with clients for payment established his guilt. The Court emphasized that the credibility of the victim’s testimony, when found credible by the trial court, is accorded great weight. All penalties and awards of damages by the lower courts were sustained, with modifications to the interest rate on monetary awards in accordance with prevailing jurisprudence.