G.R. No. 262632 , June 05, 2024
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. SI YOUNG OH A.K.A. “STEVE OH,” ACCUSED-APPELLANT.

FACTS

Accused-appellant Si Young Oh, a pastor, operated the “South Korea/◼◼◼◼” in Pampanga, offering theology courses without a government permit. Following reports of exploitation, a rescue operation on April 15, 2013, led to his apprehension and indictment for Qualified Trafficking in Persons under RA 9208 (Anti-Trafficking in Persons Act of 2003). The Amended Information alleged that from March 2010, he conspired to recruit, transport, harbor, and provide lodging to minors AAA, BBB, XXX, and CCC (all 17 years old) and others for forced labor or involuntary servitude. Upon arraignment, Si Young Oh pleaded not guilty. The prosecution presented victims AAA, BBB, and CCC. AAA and BBB, recruited from South Cotabato, testified they were made to perform manual construction labor (e.g., carrying hollow blocks, welding) from 8:00 a.m. until 3:00 a.m. the next day for little (PHP 50-200) or no pay, under the supervision of Si Young Oh and Lee Yeon Ho, believing they had no choice as they were promised theological studies. CCC, recruited in Manila at age 15, gave similar testimony about construction work and receiving small allowances. The defense presented Si Young Oh and a former student, Jonathan Requita. Si Young Oh admitted operating without a permit and that some students were minors but claimed the labor was voluntary and part of Christian service, with work hours from 9:00 a.m. to 1:00-4:00 p.m. Jonathan corroborated the voluntariness claim. The RTC found Si Young Oh guilty, sentencing him to life imprisonment and a PHP 1,000,000 fine, and ordered him to pay PHP 50,000 moral damages to each victim, while acquitting Lee Yeon Ho. The CA affirmed the conviction with modifications to the damages. Si Young Oh appealed.

ISSUE

Whether the Court of Appeals erred in affirming accused-appellant Si Young Oh’s conviction for Qualified Trafficking in Persons.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the CA Decision with MODIFICATIONS. The Court held that all elements of Qualified Trafficking in Persons under Section 4(a) in relation to Section 6(a) and (c) of RA 9208 were proven beyond reasonable doubt. The acts of recruitment and transportation of the victims (AAA, BBB, CCC) were established through their consistent testimonies. The purpose of forced labor or involuntary servitude was proven by evidence that the minors were coerced into exhaustive construction work under exploitative conditions with minimal or no pay, leveraging Si Young Oh’s moral ascendancy as a pastor and head of the institution. The minority of the victims (all below 18) at the time of the commission was proven by their birth certificates, qualifying the trafficking under Section 6(a). The crime was also committed in large scale under Section 6(c) as it was committed against three or more persons. The defenses of denial and voluntary labor were rejected for being self-serving and uncorroborated. The penalty of life imprisonment and a fine of PHP 2,000,000 (as modified by the CA) were affirmed. The award of damages was modified: moral damages increased to PHP 500,000, civil indemnity set at PHP 500,000, and exemplary damages set at PHP 100,000 to each victim, with 6% interest per annum on all damages from finality of judgment until full payment. The Court emphasized the grave nature of trafficking and the state’s duty to protect the vulnerable.