People v. De Castro

G.R. No. 274959 · 2025-04-23 · J. LAZARO-JAVIER, J.: · Primary: Criminal; Secondary: [null]
REITERATION

Facts

The Antecedents: On February 13, 2018, the Anti-Human Trafficking Division of the National Bureau of Investigation (NBI) received a referral letter from the xxxxxxxxxxx City Social Welfare and Development Department concerning rampant sexual exploitation. An entrapment and rescue team was formed, designating NBI Agent Don Syrel Bati (Agent Bati), NBI Special Investigator Joselito Valle (Agent Valle), and IACAT Intelligence Agents Jerome Bagon and Mark Joshua Santos as poseur customers. Around 1:00 a.m. on February 14, 2018, at xxxxxxxxxxx, accused-appellant Ryan De Castro y Serrano (De Castro) and Renato Hernandez y Beltran (Hernandez) approached the poseur customers, offering the sexual services of four girls (AAA, BBB, CCC, and DDD) for PHP 500.00 each. Agent Bati handed PHP 2,000.00 in marked money to De Castro, signaling the consummation of the transaction. De Castro and Hernandez were then arrested, and De Castro threw the money on the ground when operatives attempted to retrieve it. Victim BBB corroborated the operatives' testimony, stating that De Castro called her and the other victims, explicitly telling them, "Tara, punta tayo doon kasi may kausap kam[i]" and that they knew they were being offered for sexual activities for PHP 500.00 each, expecting PHP 300.00 for themselves. Procedural History: De Castro and Hernandez were charged with violation of Section 4(e) in relation to Section 6(c) of Republic Act No. 9208 (Anti-Trafficking in Persons Act of 2003), as amended by Republic Act No. 10364 (Expanded Anti-Trafficking in Persons Act of 2012). Both pleaded not guilty. Hernandez died on November 30, 2019, leading to the dismissal of the case against him. On September 5, 2022, the trial court found De Castro guilty beyond reasonable doubt of Qualified Trafficking in Persons, sentencing him to life imprisonment, a fine of PHP 2,000,000.00, and ordering him to pay PHP 500,000.00 as moral damages and PHP 100,000.00 as exemplary damages to each of the victims. The Court of Appeals, in its Decision dated January 17, 2024, affirmed the trial court's conviction in full. The Appeal: De Castro appealed to the Supreme Court, asserting his innocence and seeking acquittal. He argued that the trial court erred in disregarding his denial and relying on prosecution witnesses. Specifically, he claimed that Agent Bati testified it was Hernandez, not him, who offered women for sex, and that there could be no conspiracy as they did not appear to know each other. He maintained that he merely summoned the girls at Hernandez's request. De Castro further posited that BBB only knew him because of the case and merely assumed his involvement, and that he never spoke to BBB about selling her sexual services. He also highlighted a material inconsistency between Agent Bati's testimony (De Castro received the money) and BBB's testimony (Hernandez received the money), suggesting a fabrication of facts. The Office of the Solicitor General (OSG) countered that the prosecution established all elements of the offense and that De Castro conspired with Hernandez, as depicted by the concerted actions of offering and selling the victims for sexual exploitation.

Issue(s)

Whether the Court of Appeals erred in affirming the conviction of accused-appellant Ryan De Castro y Serrano for Qualified Trafficking in Persons; and whether the prosecution established all the elements of the offense of trafficking in persons under Section 4(e) in relation to Section 6(c) of Republic Act No. 9208, as amended by Republic Act No. 10364. Whether conspiracy between De Castro and Hernandez was proven beyond reasonable doubt. Whether the qualifying circumstance of large scale trafficking was present. Whether the alleged inconsistencies in the prosecution's testimonies regarding who received the marked money are material and sufficient to warrant acquittal.

Ruling

The Appeal is DISMISSED. The Decision dated January 17, 2024 of the Court of Appeals in CA-G.R. CR-HC No. 17339 is AFFIRMED. Accused-appellant Ryan De Castro y Serrano is found GUILTY beyond reasonable doubt of Qualified Trafficking in Persons under Section 4(e) in relation to Section (6)(c) of Republic Act No. 9208, as amended, by Republic Act No. 10364. He is sentenced to life imprisonment and ordered to PAY a fine of PHP 2,000,000.00. He is also ordered to PAY each of the victims, namely: AAA, BBB, and CCC PHP 500,000.00 as moral damages and PHP 100,000.00 as exemplary damages. All monetary awards are subject to 6% interest per annum from finality of this Decision until full payment.

Ratio Decidendi

On Issue 1: The Supreme Court found no error in the Court of Appeals' affirmation of De Castro's conviction. The Court reiterated that the gravamen of trafficking in persons is the act of recruiting or using a human being for sexual exploitation, as held in People v. Barrientos. The lower courts' concurrent findings on the credibility of prosecution witnesses are accorded great weight, especially since De Castro failed to impute any ill motive to them, consistent with People v. Deniega. The Court emphasized that the prosecution successfully established all elements of the offense and the qualifying circumstance, which were affirmed by both the trial court and the Court of Appeals. Therefore, the appeal was dismissed, and the conviction was upheld. The Court held that the prosecution successfully established all three elements of trafficking in persons under Republic Act No. 9208, as amended by Republic Act No. 10364, as laid down in People v. Casio. First, the act of 'offering' persons for sexual exploitation was proven by Agent Bati and Agent Valle's testimonies that De Castro initially approached them, offering the sexual services of four women for PHP 500.00 each. This was corroborated by BBB, who testified that De Castro explicitly told her and the other victims, "May kukuha daw ng babae, apat," which, in context, meant availing sexual services. Second, the means used involved 'taking advantage of the vulnerability of the person,' as the victims' underprivileged status compelled them to engage in such activities for a meager sum, consistent with People v. Leocadio. Third, the purpose was clearly 'sexual exploitation' or 'prostitution of others,' as evidenced by the offer of sexual services for money. De Castro's denials were contradicted by his own admission of acquaintance with Hernandez and BBB's testimony that she knew De Castro a week prior to the arrest. On Issue 2: The Supreme Court affirmed that conspiracy between De Castro and Hernandez was proven beyond reasonable doubt. Conspiracy exists when two or more persons agree to commit a crime and decide to commit it, as established in People v. Gerero. Direct proof of conspiracy is not required; proof of concerted action suffices, as noted in People v. Hernandez, G.R. No. 265754. De Castro's actions, including approaching the poseur customers, summoning the victims upon Hernandez's instruction, and telling the victims that "may kukuha daw ng babae, apat," clearly demonstrated a singularity of intent and unity in execution of the unlawful objective to offer the victims for sexual exploitation. Thus, even if Hernandez also participated, De Castro became complicit and equally liable as a co-principal, as the act of one is the act of all in a conspiracy, citing People v. Dongcoy. On Issue 3: The Court found that the qualifying circumstance of large scale trafficking was indeed present. Section 6(c) of Republic Act No. 9208, as amended, explicitly states that trafficking is deemed committed in large scale "if committed against three (3) or more persons, individually or as a group." The prosecution clearly established that at least three victims, namely AAA, BBB, and CCC, were involved in the transaction. This factual finding, consistently upheld by the lower courts, directly satisfies the statutory definition for large scale trafficking, thereby qualifying the offense and warranting the higher penalty. On Issue 4: The Court held that the alleged inconsistency regarding who received the PHP 2,000.00 marked money (Agent Bati testified De Castro, while BBB testified Hernandez) was not material and did not warrant De Castro's acquittal. The Court of Appeals correctly found that De Castro conspired with Hernandez to sexually exploit the victims. In a conspiracy, the act of one is the act of all, and it becomes immaterial who actually received the money, as long as there is a concerted action towards the unlawful objective, as reiterated in People v. Hernandez, G.R. No. 265754. The focus is on the shared intent and unified execution of the crime, not on minor details of execution. The Court accords great weight to the concurrent findings of the courts below with respect to the credibility of prosecution witnesses, especially when no ill motive is proven against them.

Main Doctrine

The primary legal doctrine established and applied in this case concerns the elements and qualification of the crime of Trafficking in Persons under Republic Act No. 9208, as amended by Republic Act No. 10364. The Court reiterates that the offense involves the act of offering or providing persons for sexual exploitation, utilizing means such as taking advantage of vulnerability, for the purpose of prostitution or other forms of sexual exploitation. Furthermore, the case clarifies that the crime is qualified as 'large scale' when committed against three or more persons, emphasizing that conspiracy in such acts renders all participants equally liable, regardless of the extent of their individual participation, as long as there is a singularity of intent and unity in execution of the unlawful objective.

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