People v. XXX270897
REITERATIONFacts
1. The Antecedents: Accused-appellant XXX270897 was charged with three counts of qualified trafficking in persons under RA 9208, as amended, involving minor victims AAA270897 (14-15 years old, September 2014, received via friend DDD270897 at motel, paid PHP 500 despite no intercourse), CCC270897 (15 years old, April 2014, received via friends Rizza and Nica, paid PHP 1,500 for intercourse, later recruited others), and BBB270897 (14 years old, September 19, 2014, received via DDD270897, paid PHP 2,500 for intercourse). Victims exploited due to poverty/runaway status; accused directed minors to recruit virgins, paying fees. Apprehended via entrapment on November 5, 2014. 2. Procedural History: RTC convicted accused of three counts (November 25, 2020), imposing life imprisonment and fines per count, moral/exemplary damages. CA affirmed via Amended Decision (September 18, 2023), dismissing appeal for procedural lapses but finding guilt proven. 3. The Appeal: Direct appeal to Supreme Court from CA Amended Decision; accused argued insufficiency of informations (missing 'means' element, payments to victims not controllers), lack of knowledge of minority, consent/voluntariness, and trial judge bias via overruled objections.
Issue(s)
Whether the informations sufficiently alleged all elements of qualified trafficking in persons. Whether the prosecution proved accused-appellant's guilt beyond reasonable doubt. Whether the trial court judge was biased and partial. Propriety of penalty and damages.
Ruling
ACCORDINGLY, the appeal is DISMISSED. The Amended Decision dated September 18, 2023 of the Court of Appeals in CA-G.R. CR-HC No. 02767-MIN convicting accused-appellant XXX270897 of three counts of qualified trafficking in persons under Section 4(a), in relation to Section 6 of Republic Act No. 9208, as amended by Republic Act No. 10364 is AFFIRMED. Accused-appellant is sentenced to life imprisonment and ORDERED to PAY a fine of PHP 2,000,000.00 for each count. He is further ORDERED to pay each of the victims PHP 500,000.00 as moral damages and PHP 100,000.00 as exemplary damages and to pay the cost of suit. All monetary amounts shall earn legal interest at the rate of 6% per annum from the finality of this Decision until full payment.
Ratio Decidendi
On Issue 1: Whether the informations sufficiently alleged all elements of qualified trafficking in persons: The Supreme Court held the informations sufficient under Rule 110, Sections 6, 8, 9, as they stated the designation of offense, acts (willfully received/hired minor victims whose age known, through another minor directed to provide services for sexual intercourse for a fee), offended parties, date, and place. Applying People v. Casio, elements are: (1) act of receipt; (2) means (implied via payment/receipt for consent of controller, vulnerability); (3) purpose of exploitation; qualified by minority alleged. No need for statutory language; ordinary concise terms suffice for common understanding and judgment. For minors, means element dispensable per People v. Celis and People v. Hernandez, as RA 9208 Sec. 3(a) deems recruitment/receipt of child for exploitation as trafficking even without means. Thus, averments of receiving minors for fee-based sex via pimp minor met all requisites. On Issue 2: Whether the prosecution proved accused-appellant's guilt beyond reasonable doubt: The Court adopted RTC/CA findings, crediting victims' birth certificates for minority and categorical testimonies detailing receipt via minor recruiters for paid sex, exploiting poverty/vulnerability. AAA270897 testified recruitment by DDD270897 for sex/money, no intercourse needed per People v. Dela Cruz. CCC270897 detailed text invitation, payment PHP 1,500, intercourse, later recruitment. BBB270897 similar via DDD270897, PHP 2,500 post-intercourse. Consent irrelevant for minors; trial court credibility assessment binding absent overlooked facts, victims 'direct, candid' under cross-exam. Accused's scheme of directing minors to recruit proven, establishing guilt. On Issue 3: Whether the trial court judge was biased and partial: Imputation baseless; divergence in rulings on objections/law application not bias per People v. Kho. Judge acted impartially; repeated adverse rulings not disqualification ground if evidence-based. On Issue 4: Propriety of penalty and damages: Penalty of life imprisonment and PHP 2,000,000 fine per count proper under RA 9208 Sec. 10(e); damages PHP 500,000 moral, PHP 100,000 exemplary with 6% interest from finality per People v. Estonilo, Sr.
Main Doctrine
In qualified trafficking in persons involving minor victims under Section 4(a) of RA 9208, as amended, the prosecution need not prove the 'means' element (e.g., threat, force, coercion) because the law carves an exception for children, recognizing their inherent vulnerability; it suffices to establish the act of recruitment, receipt, or harboring and the purpose of sexual exploitation, with the victim's minority proven by birth certificate. Consent of the minor is irrelevant as minors cannot legally consent, rendering the crime consummated even without completed sexual intercourse. This protects minors as parens patriae, shifting focus to exploitation via payments or vulnerability like poverty, as applied in cases like People v. Casio and People v. Celis, ensuring swift prosecution without technical hurdles.