G.R. No. 240692 . July 15, 2020.
People of the Philippines, Plaintiff-Appellee, vs. Imelda Garcia y Tordedo and Noel E. Oledan, Accused, Noel E. Oledan, Accused-Appellant.

FACTS

The case involves an appeal from a conviction for Qualified Trafficking in Persons under RA 9208 (Anti-Trafficking in Persons Act of 2003). The Information charged accused-appellant Noel E. Oledan with recruiting and hiring AAA, a minor, for prostitution. AAA was 15 years old when introduced to Oledan by a neighbor in Pasay City on September 16, 2009. Oledan offered her work at Saigon Disco in Laoag City, explaining she would drink liquor and be “bar fined” (have sexual intercourse with customers) for money. Knowing AAA was a minor, Oledan instructed her to provide a Certificate of Live Birth of another person (Darlene B. Fernandez) to use. Without her mother’s consent, AAA traveled with Oledan to Laoag City. At Saigon Disco, Oledan introduced AAA to the floor manager, Imelda Garcia. AAA received an advance payment from the owners and began working, which involved drinking with customers and being “bar fined.” She worked for three months, was managed by Oledan and Garcia, was not allowed to leave, and was not given a regular salary. AAA’s mother, BBB, after learning her daughter’s whereabouts and suspecting she was held by a syndicate, sought help from the International Justice Mission and filed a report with the NBI. An entrapment operation was conducted on December 12, 2009, leading to the arrest of Garcia after she received marked money for AAA’s “bar fine.” Oledan denied the charges, claiming AAA was introduced to him by Tita Butz, that AAA misrepresented her age and identity, and that upon discovering she was a minor, he and Garcia advised her to go home but allowed her to work as a waitress.

ISSUE

Whether the Court of Appeals correctly affirmed the conviction of accused-appellant Noel E. Oledan for the crime of Qualified Trafficking in Persons.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the Decision of the Court of Appeals with MODIFICATION. The Court held that all elements of Qualified Trafficking in Persons were present: (1) the act of “recruiting, transporting, transferring, harboring, providing, or receiving a person” includes maintaining or hiring a person for prostitution; (2) the means employed, such as fraud, deception, abuse of vulnerability, or giving payments; and (3) the purpose of exploitation, which includes prostitution. The qualifying circumstance of minority was also established, as AAA was 15 years old at the time of recruitment. The Court found AAA’s testimony credible and consistent, detailing how Oledan recruited her, facilitated her travel, and maintained her in a prostitution scheme. Oledan’s defenses of denial and frame-up were rejected for being weak and unsupported by evidence. The crime was qualified by the victim’s minority, warranting the penalty of life imprisonment and a fine of Two Million Pesos (P2,000,000.00). The Court modified the award of damages, ordering Oledan to pay AAA P500,000.00 as civil indemnity, P500,000.00 as moral damages, and P100,000.00 as exemplary damages, all with legal interest.