G.R. No. 253629 . September 28, 2022.
Lenida T. Maestrado, Petitioner, vs. People of the Philippines, Respondent.

FACTS

Petitioner Lenida Maestrado, along with co-accused Jenylin Alvarez, Stephanie Locker, and Rubelyn Stone, was charged with Attempted Trafficking in Persons under RA 9208 (Anti-Trafficking in Persons Act), as amended. The Information alleged they conspired to simulate the birth of a 7-month-old child, AAA, and acquire custody from her low-income family for the purpose of selling her. Locker and Stone remained at-large. The prosecution established that on September 24, 2014, Locker, Stone, and Alvarez went to the Local Civil Registrar to register AAA’s birth, presenting a marriage certificate of Caucasian parents and a form listing Alvarez as the attending midwife. A birth certificate was issued falsely stating AAA was born to American parents. An investigation, prompted by U.S. authorities noting the child appeared Filipino while the listed parents were Caucasian, revealed AAA’s true biological mother was BBB. AAA was found in Maestrado’s custody.
Maestrado denied conspiracy, claiming she merely cared for AAA as a favor to Stone, who was the child’s godmother. She asserted she had no knowledge of the simulated birth registration. The Regional Trial Court found Maestrado and Alvarez guilty beyond reasonable doubt of attempted trafficking. The Court of Appeals affirmed the conviction, ruling that the acts of simulating a birth certificate to falsely attribute parentage constituted an overt act in the attempted execution of the crime of trafficking for the purpose of selling the child.

ISSUE

Whether the Court of Appeals erred in affirming petitioner Maestrado’s conviction for the crime of Attempted Trafficking in Persons.

RULING

The Supreme Court denied the petition and affirmed the conviction. The legal logic centered on the elements of attempted trafficking under Section 4-A of RA 9208, as amended. For attempted trafficking, the prosecution must prove the accused commenced the commission of the crime directly by overt acts but did not perform all acts of execution due to some cause or accident other than their own spontaneous desistance. The Court found these elements present. The acts of simulating AAA’s birth by procuring and filing a falsified birth certificate, which falsely declared the child as born to foreign nationals, constituted a direct overt act toward the purpose of selling the child. This simulation was a crucial step to facilitate the child’s illegal adoption or sale by creating fraudulent documentation of a different identity and parentage.
The Court rejected Maestrado’s defense of lack of knowledge and conspiracy. Conspiracy was deduced from the collective and coordinated actions of the accused, demonstrating a common purpose. Maestrado’s act of taking custody of AAA, coupled with the fabricated birth certificate created by her co-accused, formed an unbroken chain leading to the attempted trafficking. Her custody of the child under the guise of being a mere caretaker, when viewed in conjunction with the fraudulent registration, indicated participation in the scheme. The attempt was not consummated only because law enforcement intervened. Thus, the lower courts correctly found her guilt proven beyond reasonable doubt, upholding the state’s policy to protect children from exploitation.