GR 273990; (January, 2025) (Digest)
G.R. No. 273990, January 22, 2025
People of the Philippines, Plaintiff-Appellee, vs. XXX, Accused-Appellant.
FACTS
Accused-appellant XXX was charged with Qualified Trafficking in Persons for recruiting two 14-year-old minors, AAA and BBB, to work as massage therapists at a spa from August 26 to September 5, 2019, for the purpose of prostitution and sexual exploitation. The minors testified that accused-appellant, whom they knew as the mother of a friend, invited them to work, taught them massage techniques, and instructed them about providing “extra services” (described as sexual intercourse) to customers for money. AAA escaped from the spa after her request to go home was denied, while BBB was sent home after accused-appellant’s arrest. The defense presented witnesses, including accused-appellant, who claimed the minors sought employment voluntarily and that instruction on “extra services” came from another person at the spa, not from her. The parties stipulated that dental examinations confirmed AAA and BBB were minors. The Regional Trial Court (RTC) convicted accused-appellant of the lesser offense of Attempted Trafficking in Persons. The Court of Appeals (CA) modified the RTC decision, finding her guilty of Qualified Trafficking in Persons.
ISSUE
Whether the Court of Appeals erred in convicting accused-appellant of Qualified Trafficking in Persons.
RULING
The Supreme Court denied the appeal and affirmed the CA decision. The Court held that all elements of Qualified Trafficking in Persons under Republic Act No. 9208, as amended, were proven beyond reasonable doubt: (1) the act of recruitment of AAA and BBB; (2) the means employed, which included abuse of the victims’ vulnerability due to minority; and (3) the purpose of exploitation, which was sexual exploitation or prostitution. The minority of the victims was established by stipulation and constituted a qualifying circumstance. The Court found the testimonies of the minor victims credible and consistent, demonstrating that accused-appellant recruited them with the intent to exploit them for sexual services. The defense of lack of malicious intent and voluntary employment was rejected. The penalty imposed by the CA was affirmed: life imprisonment and a fine of Two Million Pesos (PHP 2,000,000.00), with awards of moral damages, exemplary damages, and interest.