People v. Bautista
REITERATIONFacts
The Antecedents: In November 2017, AAA270003, a 14-year-old minor, received a call from an unknown number later identified as Ria Liza Bautista y Cariaga (Bautista), asking if she was 'xxxxxxxxxxx' and inviting her to stay at a specific location, which AAA270003 declined. On November 23, 2017, AAA270003 met Bautista at her boarding house, stayed overnight, and after feigning a stomach ache to buy medicine, Bautista instead took her around and began pimping her to men for money, accompanied by Bautista's constant companion Nicole. On November 24, 2017, Bautista transported AAA270003 to a police camp in xxxxxxxxxxx, where she pimped her to a former soldier over 50 years old; the soldier had vaginal intercourse with AAA270003 inside a room while Bautista and Nicole waited outside, after which the soldier paid Bautista PHP 1,500, and Bautista gave AAA270003 PHP 1,000, saying 'this is your money.' The next day, November 25, 2017, Bautista contacted AAA270003 again; they went to a computer shop where Bautista received a call for 'girls,' then proceeded to xxxxxxxxxxx hotel, where Bautista instructed AAA270003 to enter a room with a man over 30 years old waiting upstairs; AAA270003 entered, was undressed, begged off due to abdominal pain, and fled without intercourse occurring, yet Bautista still gave her PHP 700 upon return to the computer shop without reaction. In the early morning of another day in November 2017, Bautista introduced AAA270003 to her friend Arnel at a gasoline station in xxxxxxxxxxx; two men on a motorcycle joined them, and they all went to xxxxxxxxxxx hotel, where Bautista instructed AAA270003 to enter a room with one soldier-customer who had carnal knowledge of her for 10 minutes, paying PHP 2,500, of which PHP 2,000 went to AAA270003 and PHP 500 to Bautista; this was the last instance as AAA270003 stopped associating with Bautista. AAA270003 later confided in her mother, who took her to the police station to report and prevent further victimization. Procedural History: Bautista was charged via Information for qualified trafficking in persons under RA 9208, as amended; she pleaded not guilty, pre-trial ensued where parties admitted AAA270003's minority, and trial on merits followed. The RTC (Branch xxxx, xxxxxxxxxxx) convicted Bautista on May 22, 2020, sentencing her to life imprisonment, P2M fine, P500K moral damages, and P100K exemplary damages. Bautista appealed to the CA (CA-G.R. CR-HC No. 14678), which affirmed with modification on February 16, 2023, adding 6% interest per annum on damages from finality. Bautista appealed to the Supreme Court via Notice of Appeal. The Petition: Bautista denied pimping AAA270003, claiming the accusation stemmed from AAA270003's argument with Nicole; she argued lack of proof that she convinced AAA270003 to engage in prostitution, no explicit vulnerability exploitation, and that AAA270003's consent or will determined the acts, seeking acquittal for failure to prove elements beyond reasonable doubt.
Issue(s)
Whether accused-appellant Ria Liza Bautista y Cariaga is guilty beyond reasonable doubt of qualified trafficking in persons under Republic Act No. 9208, as amended.
Ruling
The Appeal is DISMISSED. The CA Decision is AFFIRMED. Accused-appellant is GUILTY beyond reasonable doubt of qualified trafficking in persons, sentenced to life imprisonment and P2,000,000 fine; ordered to pay AAA270003 P500,000 moral damages and P100,000 exemplary damages, with 6% interest per annum from finality until fully paid.
Ratio Decidendi
On the Issue of Guilt for Qualified Trafficking: The Court exhaustively detailed the three elements from People v. Casio: (1) Bautista recruited, offered, and transported AAA270003—a proven minor via judicial admission in pre-trial, her testimony of being 14 at incidents (TSN, Sept. 4, 2019), and Bautista's cross-exam admission—to different men (former soldier on Nov. 24, hotel man on Nov. 25, soldier via Arnel), as shown in verbatim testimonial excerpts spanning three incidents where Bautista solicited via phone, accompanied to sites, waited outside during sexual acts, and handled/distributed payments (PHP1,500→1,000; PHP700 partial; PHP2,500→2,000+500 commission). (2) Means involved taking advantage of AAA270003's vulnerability as a child, unnecessary to prove explicit coercion per Section 3(a), par. 2, RA 9208, as amended—reiterated from People v. Dela Cruz (904 Phil. 566) that for minors, recruitment for exploitation suffices, consent is immaterial/irrelevant due to presumed coerciveness of age (People v. Casio, 749 Phil. 458 at 475-476), rejecting Bautista's claim of no conviction proof. (3) Purpose was prostitution/sexual exploitation, evident from pimping to customers for fees from which Bautista benefited via commissions, undisputed. Positive, detailed testimony of AAA270003—credible as trial court observed deportment—prevails over Bautista's bare denial/self-serving claim of motive from Nicole spat, as denial is weak sans strong evidence (People v. San Miguel, 887 Phil. 777). Crime qualified under Section 6(a) by child's status, warranting life imprisonment and P2M fine minimum per Section 12(e), RA 10364; 6% interest on damages proper per jurisprudence (People v. Dela Cruz at 589-590).
Main Doctrine
Trafficking in persons is committed through recruitment, obtaining, hiring, providing, offering, transportation, transfer, maintaining, harboring, or receipt of persons, including children, for exploitation such as prostitution or sexual exploitation, even without the victim's consent or specific coercive means when the victim is a child below 18 years old. For child victims, the act of recruitment or transportation for exploitative purposes alone suffices, as the law deems minors inherently vulnerable, rendering consent immaterial and irrelevant. The crime is qualified when the trafficked person is a child, mandating life imprisonment and a fine of at least P2,000,000. Positive, credible testimony of the victim prevails over the accused's bare denial, which is intrinsically weak without corroboration. Judicial admissions on the victim's minority during pre-trial are binding and require no further proof. The perpetrator's role in procuring customers, waiting outside during sexual acts, and taking commissions establishes the purpose of exploitation.