G.R. No. 273190, October 16, 2024
PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XXX, ACCUSED-APPELLANT.

FACTS

Accused-appellant XXX was charged with Qualified Trafficking in Persons under Section 4(a) in relation to Section 6(a) of Republic Act (R.A.) No. 9208 (Criminal Case No. FC-13-1155) and with violations of Sections 5(b) and 10(a) of R.A. No. 7610 (Criminal Case Nos. FC-13-1156 to FC-13-1158). The prosecution alleged that in August 2010, XXX, by means of force, threats, and coercion, received the 15-year-old minor AAA at a port, transported her to various locations and a videoke bar, and harbored and employed her as a prostitute for exploitation, receiving commissions therefrom. Further charges involved acts of child abuse, including physical harm and inducing AAA to engage in sexual intercourse by forcing her to take shabu. During pre-trial, the parties stipulated on XXX’s identity, AAA’s minority, and that they met in August 2007. The prosecution presented AAA, her co-worker BBB, and a social worker. AAA testified that XXX transported her for prostitution, received payments from clients, withheld her salary, and physically abused her. BBB reported AAA’s situation, leading to a rescue operation. The defense presented XXX, who denied the allegations, claiming he was a tricycle driver unaware of AAA’s prostitution and that she had misrepresented her age. The Regional Trial Court (RTC) convicted XXX of qualified trafficking but acquitted him of the R.A. No. 7610 charges. The Court of Appeals (CA) affirmed the RTC’s decision.

ISSUE

Whether the Court of Appeals erred in affirming the conviction of accused-appellant XXX for Qualified Trafficking in Persons.

RULING

The Supreme Court DENIED the appeal and AFFIRMED the conviction. The Court held that all elements of Qualified Trafficking in Persons under Section 4(a) of R.A. No. 9208, as amended by R.A. No. 10364, were proven beyond reasonable doubt: (1) the act of “receiving” and “transporting” the victim; (2) the means employed, which included “coercion” and “abuse of power or position” given AAA’s minority and the exploitative context; (3) the purpose of exploitation, specifically prostitution and sexual exploitation; and (4) the victim was a minor, a qualifying circumstance that raises the penalty to life imprisonment and a fine. The stipulation of AAA’s minority during pre-trial was binding and conclusive. The Court found AAA’s testimony credible, consistent, and corroborated on material points, sufficiently establishing XXX’s acts of recruiting, transporting, and benefiting from AAA’s prostitution. His defenses of denial and frame-up were weak and could not prevail over the positive identification and credible testimony of the victim. The acquittal for violations of R.A. No. 7610 does not affect the trafficking conviction, as these are distinct offenses with different elements.