People v. Bandojo
REITERATIONFacts
The Antecedents: Accused-appellants Ludivico Patrimonio Bandojo, Jr. and Kenny Joy Villacorta Ileto were charged with Qualified Trafficking in Persons and Trafficking in Persons for recruiting and hiring AAA, a 17-year-old minor, to engage in sexual intercourse with clients for monetary consideration, taking advantage of her vulnerability for prostitution and sexual exploitation. A second victim, BBB, was also involved in a similar charge. Procedural History: The Regional Trial Court (RTC) of Manila convicted the accused-appellants for Qualified Trafficking in Persons in Criminal Case No. 12-293693 but acquitted them in Criminal Case No. 12-293694. The Court of Appeals (CA) affirmed the conviction with modifications regarding damages. The accused-appellants appealed to the Supreme Court. The Petition: The accused-appellants argued that the prosecution failed to prove their guilt beyond reasonable doubt, that conspiracy was not established, and that their defense of denial was disregarded. They contended that AAA initiated the request for 'rakets' and that they did not know she was a minor.
Issue(s)
Whether the prosecution was able to prove beyond reasonable doubt the guilt of the accused-appellants for the crime of human trafficking. Whether the RTC erred in finding the presence of conspiracy. Whether the RTC erred in disregarding the accused-appellants' defense of denial.
Ruling
The Supreme Court affirmed the conviction of Ludivico Patrimonio Bandojo, Jr. and Kenny Joy Villacorta Ileto for Qualified Trafficking in Persons under Section 4(a), in relation to Section 6(a), of Republic Act No. 9208. The Court imposed the penalty of life imprisonment and a fine of Php 2,000,000.00 each, and ordered them to jointly and severally pay the victim Php 500,000.00 as moral damages and Php 100,000.00 as exemplary damages, with legal interest.
Ratio Decidendi
On the issue of whether the prosecution proved the guilt of the accused-appellants beyond reasonable doubt: The Court found that all elements of Qualified Trafficking in Persons were established. The testimony of AAA and NBI Agent Señora proved the recruitment, transportation, and exploitation for prostitution. The fact that AAA was 17 years old at the time of the offense qualified the crime. The entrapment money recovered from Ludivico, positive for fluorescent powder, further corroborated the prosecution's evidence. The Court reiterated that the consent of the victim is not a defense under R.A. No. 9208, especially when the vulnerability of the person is taken advantage of. Furthermore, knowledge of the victim's minority is immaterial for the crime to be qualified under Section 6(a) of R.A. No. 9208. On the issue of whether the RTC erred in finding the presence of conspiracy: The Court held that conspiracy can be inferred from the parties' conduct indicating a common understanding and a joint purpose. The concerted actions of Ludivico and Kenny Joy in arranging and facilitating the prostitution of AAA, including receiving the down payment and bringing the victim to the hotel, demonstrated a common design to commit the crime. Their meeting on the day of the arrest did not negate conspiracy, as it could be deduced from their coordinated actions. On the issue of whether the RTC erred in disregarding the accused-appellants' defense of denial: The Court reiterated the principle that a categorical and consistent positive identification by witnesses prevails over mere denial. The accused-appellants were positively identified by AAA and Agent Señora. Their unsubstantiated denial could not overcome the credible testimonies of the prosecution witnesses, especially in the absence of any ill motive attributed to them. The Court found no error in the RTC's rejection of their defense.
Main Doctrine
The consent of a minor victim is not a defense in human trafficking cases, as the law explicitly states that trafficking can be committed with or without the victim's consent or knowledge, and the exploitation of a minor's vulnerability is a key element. Furthermore, knowledge of the victim's minority is inconsequential for qualifying the crime of Trafficking in Persons under Section 6(a) of R.A. No. 9208.