G.R. No. 234013 , June 16, 2021
People of the Philippines, Plaintiff-Appellee, vs. Mitchelle Valencia y Dizon and Joane Simbillo y Lauretti, Accused-Appellants.

FACTS

Accused-appellants Mitchelle Valencia and Joane Simbillo were charged with eight counts of trafficking in persons under Section 4(a) of Republic Act No. 9208 (the Anti-Trafficking in Persons Act of 2003), as amended. One Information (Criminal Case No. 14-11900) charged Simbillo for offering AAA for sexual exploitation sometime in February 2014. Seven other Informations (Criminal Case Nos. 14-11901 to 14-11907) charged both Valencia and Simbillo for acts committed on May 27, 2014, involving minors BBB (13), CCC (14), DDD (13), EEE (11), FFF (14), GGG (12), and HHH (15). The charges alleged they recruited and provided these individuals for prostitution with foreigners for payment, taking advantage of their financial need.
The Regional Anti-Trafficking Task Group conducted an entrapment operation on May 26, 2014, after surveillance confirmed Valencia and Simbillo were offering minors for sexual services along Fields Avenue, Angeles City. During the operation, PO3 Mendoza, acting as a driver for a foreigner asset, witnessed Valencia and Simbillo offer minors for P1,500.00 each. After the asset agreed to pay, the victims boarded a van, at which point the police team arrested Valencia and Simbillo and rescued the victims. The marked money was recovered.
During trial, victims AAA, CCC, and DDD testified that Simbillo and Valencia had previously facilitated their sexual exploitation for money on earlier occasions. Victims CCC, DDD, EEE, GGG, HHH, and BBB testified that on May 26, 2014, Simbillo and Valencia approached them under the pretext of being fed by a foreigner, but were instead brought for prostitution.
The defense denied the charges, claiming they were framed. They alleged Valencia worked in a sari-sari store and a foreigner merely asked her to invite girls so he could feed them.
The Regional Trial Court found them guilty. The Court of Appeals affirmed the conviction. Hence, this appeal.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of accused-appellants for trafficking in persons.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the convictions with MODIFICATIONS to the penalties.
The Court held that all elements of trafficking under RA 9208, as amended, were proven. The acts of recruiting, obtaining, and offering persons for sexual exploitation were established. The means employed—taking advantage of the victims’ vulnerability and financial need—were present. The purpose of sexual exploitation and prostitution was clear.
The warrantless arrest following the entrapment operation was valid as the accused were caught in flagrante delicto. Entrapment is a valid means to apprehend perpetrators and rescue victims in trafficking cases.
The testimonies of the victims and the arresting officer were credible, consistent, and sufficient to sustain conviction. The defense of frame-up was rejected for being weak and unsupported by clear and convincing evidence.
The Court modified the penalties. For trafficking of minors (Criminal Case Nos. 14-11901 to 14-11906), the crime is qualified trafficking under Section 6(a) of RA 9208. The proper penalty is life imprisonment and a fine of P2,000,000.00 to P5,000,000.00. For trafficking of a 15-year-old (Criminal Case No. 14-11907) and for the act against AAA (Criminal Case No. 14-11900), the penalty under Section 4(a) is imprisonment of 20 years and a fine of P1,000,000.00 to P2,000,000.00. All fines shall earn legal interest at 6% per annum from finality until full payment.