GR 213760; (July, 2019) (Digest)
G.R. No. 213760, July 1, 2019
REYNALDO SANTIAGO, JR. y SANTOS, Petitioner, vs. PEOPLE OF THE PHILIPPINES, Respondent.
FACTS
Petitioner Reynaldo Santiago, Jr. was charged with qualified trafficking in persons under Republic Act No. 9208 (The Anti-Trafficking in Persons Act of 2003). The Information alleged that on September 30, 2011, in Manila, Santiago, acting as part of a syndicate, offered a person, AAA, for sexual intercourse for a fee to a police asset. The prosecution established that a TV5 crew, after an initial investigation using a confidential asset, reported the prostitution activity to the police, leading to an entrapment operation. During the operation, the asset pointed out the pimps, including Santiago, who were subsequently arrested. AAA testified that Santiago recruited her, offering her ₱350 out of a ₱500 fee to spend the night with a customer, and escorted her to a nearby hotel where the police intervened.
Santiago, testifying in his defense, claimed he was merely selling coffee when the asset approached him, which he ignored. He alleged that AAA later invited him to accompany her to the hotel, where he was arrested upon arrival. The Regional Trial Court convicted Santiago under Section 4(a) of R.A. 9208, sentencing him to twenty years imprisonment and a fine of one million pesos. The Court of Appeals affirmed the conviction. Santiago elevated the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Whether the prosecution proved beyond reasonable doubt that petitioner Reynaldo Santiago, Jr. committed the crime of trafficking in persons.
RULING
Yes. The Supreme Court denied the petition and affirmed the conviction. The Court held that all elements of trafficking under Section 3(a) of R.A. 9208 were present: (1) the act of recruitment; (2) the means, which includes abuse of vulnerability; and (3) the purpose of exploitation, specifically sexual intercourse for a fee. The testimony of AAA, the trafficked person, was clear, credible, and consistent. She positively identified Santiago as the person who recruited and transported her to the hotel for the purpose of prostitution. Her testimony alone is sufficient to sustain a conviction.
The Court emphasized that the testimony of the confidential asset or informant is not indispensable for a trafficking conviction. What is crucial is proof that the accused lured or engaged the victim for the purpose of exploitation. Santiago’s defense of denial cannot prevail over AAA’s positive identification and straightforward narration of events. The trial court’s assessment of witness credibility is accorded great weight and respect. Furthermore, the absence of the marked money used in the entrapment does not negate the commission of the crime, as the essence of trafficking is the act of recruiting for exploitation, not the financial transaction itself. Therefore, the prosecution successfully established Santiago’s guilt beyond reasonable doubt.