G.R. No. 210798. September 14, 2016.
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. BEVERLY VILLANUEVA Y MANALILI @ BEBANG, ACCUSED-APPELLANT.

FACTS

The case originated from an Information charging accused-appellant Beverly Villanueva, owner/manager of On Tap Videoke Bar in Las Piñas City, with violating Section 6 of Republic Act No. 9208 (Anti-Trafficking in Persons Act). The prosecution alleged that from April 25 to May 17, 2007, Villanueva recruited and hired AAA, a 13-year-old minor, to work as a Guest Relations Officer (GRO), exploiting her vulnerability. The charge stemmed from a rescue operation initiated by AAA’s mother (private complainant) after learning her daughter was at the bar. Police, accompanied by a TV crew, conducted an operation where AAA was taken into custody. The private complainant later executed an Affidavit of Desistance, stating that after talking to AAA, she learned her daughter was merely allowed to stay at the bar after running away and was not recruited or hired as a GRO. AAA herself absconded from DSWD custody and was never presented as a witness.

ISSUE

Whether the prosecution proved beyond reasonable doubt that accused-appellant violated Section 6 of R.A. No. 9208 by recruiting and exploiting a child for labor.

RULING

The Supreme Court ACQUITTED accused-appellant Beverly Villanueva. The prosecution failed to prove her guilt beyond reasonable doubt. For a conviction under R.A. No. 9208, the act of recruitment or hiring for the purpose of exploitation must be established. The Court found the evidence presented—primarily the testimonies of PO2 Abas and the private complainant—insufficient and unreliable to prove that AAA was recruited or hired to work as a GRO. PO2 Abas had no personal knowledge of the alleged recruitment, as he was stationed outside during the operation and his testimony was based merely on the complaint. Crucially, the private complainant, the prosecution’s own witness, recanted the initial allegation through her Affidavit of Desistance and testified in court that AAA herself denied being hired or recruited. This testimony severely undermined the prosecution’s case. The Court emphasized that the burden of proof lies with the prosecution, and the defense is not obligated to prove innocence. The Affidavit of Desistance, coupled with the lack of any corroborative evidence from AAA or other direct witnesses, created reasonable doubt. The possibility that AAA was merely given shelter, not exploited for labor, remained plausible. Consequently, the element of recruitment for exploitation was not proven to a moral certainty, warranting acquittal.