GR 260639; (March, 2023) (Digest)
G.R. No. 260639 , March 29, 2023
People of the Philippines, Plaintiff-Appellee, vs. XXX, Accused-Appellant
FACTS
The National Bureau of Investigation Anti-Human Trafficking Division (NBI AHTRAD) received information on January 27, 2014, about the sexual trafficking of minors at a mall. Intelligence Agents conducted surveillance, during which accused-appellant XXX approached them and offered the sexual services of a minor for ₱1,000. An entrapment operation was conducted the following day, January 28, 2014. Accused-appellant again approached the poseur-customers (NBI agents) and offered the sexual services of minors. He instructed one of the minors, DDD, to find other girls. The four minor complainants—AAA (15), BBB (13), CCC (17), and DDD (16)—confirmed that accused-appellant acted as their pimp, receiving ₱200-₱300 from the ₱1,000 paid by customers. At a restaurant in the mall, the poseur-customers paid the marked money. Accused-appellant was then arrested, and the minors were rescued. The defense of accused-appellant was a denial, claiming he was merely shopping when invited to eat by two individuals, after which he was forcibly taken to the NBI office, and he denied knowing the complainants.
ISSUE
Whether the Court of Appeals correctly affirmed the finding of the Regional Trial Court that accused-appellant is guilty beyond reasonable doubt of Qualified Trafficking in Persons under Section 4(a) and (e) in relation to Section 6(a) and (c) of Republic Act No. 9208 (Anti-Trafficking in Persons Act of 2003), as amended by Republic Act No. 10364 .
RULING
Yes, the Court of Appeals correctly affirmed the conviction. The Supreme Court sustained the finding of guilt for Qualified Trafficking in Persons under Section 4(a) and (e) in relation to Section 6(a) of RA 9208, as amended. All elements of the crime were established: (1) the act of recruitment or harboring of persons; (2) the means, which include abuse of power or taking advantage of vulnerability; and (3) the purpose of exploitation, specifically sexual exploitation. The act fell under Section 4(a) (recruitment for prostitution) and Section 4(e) (maintaining a den for sexual exploitation). The qualifying circumstance under Section 6(a) (when the trafficked person is a child) was present, as all four victims were minors, proven by their birth certificates and testimonies. The defense of denial could not prevail over the positive and credible testimonies of the victims and the NBI agents. The penalty imposed was life imprisonment and a fine of ₱2,000,000.00, with additional awards of moral and exemplary damages to each victim.