The Supreme Court has dismissed the appeal of four accused-appellants and affirmed their conviction for qualified trafficking in persons, involving two minor victims who were recruited under the pretext of legitimate employment and later exploited for prostitution.
In Criminal Case Nos. 15320926 and 15320927, accused-appellants WWW, XXX, YYY, and ZZZ were found guilty under Section 4(a), in relation to Section 6(a) and (c) of Republic Act No. 9208, as amended by Republic Act No. 10364, and sentenced to life imprisonment and a fine of PHP 2,000,000.00 for each count.
The Case
The case stemmed from four Informations filed before the Regional Trial Court (RTC) charging several accused with violation of Section 4(a), in relation to Section 6(a), of Republic Act No. 9208, as amended by Republic Act No. 10364. Only Criminal Case Nos. 15320926 and 15320927 were involved in the appeal.
According to the prosecution, sometime in 2012, private complainant AAA — then 14 years old but who represented herself as 16 — became acquainted with ZZZ, who was looking for a person to manage her sari-sari store. ZZZ agreed to employ her for a monthly salary of PHP 3,000.00. After traveling with ZZZ, AAA worked at the store for nearly a month before ZZZ began bringing her to establishments where she was made to engage in sexual intercourse with clients. AAA was required to report every Friday and Sunday, was compelled to have sexual intercourse up to three times, and received PHP 600.00 per client — half of which was taken by ZZZ.
Private complainant BBB left to work in 2015, traveling with a certain Inday with bus fare provided by ZZZ. Upon arrival, BBB was met by ZZZ. The following day, she was assigned to a guest and compelled to have sexual intercourse, during which she cried as she could not accept the situation. She received a fixed monthly amount of PHP 7,000.00 regardless of the number of male clients she served.
The other accused-appellants performed specific roles: YYY and XXX worked as room boys who facilitated the prostitution activities, while WWW acted as a cashier who received and processed payments for the sexual services. UUU, as owner of the establishment, knowingly allowed it to be used for the activities.
The Issue
The question before the Court was whether the prosecution established all the elements of trafficking in persons under Section 4(a) of the law, and whether the offense was qualified by the victims' minority and its commission by a syndicate.
The Ruling
The Court found that the prosecution established all the elements of trafficking in persons under Section 4(a). It held that the offense was qualified under Section 6(a) and 6(c) of Republic Act No. 9208, as amended, because both victims were minors and the offense was committed by a syndicate.
In its disposition, the Court declared: "ACCORDINGLY, the Appeal is DISMISSED. The Decision dated June 28, 2024 and the Resolution dated March 25, 2025 of the Court of Appeals in CA G.R. CR-HC No. 17587 are AFFIRMED."
By the Numbers
- G.R. No. 281201
- Criminal Case Nos. 15320926 and 15320927 — cases in the appeal
- AAA and BBB — both 17-year-old minors
- AAA received PHP 600.00 per client; half taken by ZZZ
- BBB received a fixed monthly amount of PHP 7,000.00
- Life imprisonment and a fine of PHP 2,000,000.00 for each count
- PHP 500,000.00 as moral damages and PHP 100,000.00 as exemplary damages for each victim, per count
- 6% legal interest per annum from finality until fully paid
- CA Decision dated June 28, 2024; Resolution dated March 25, 2025
The Court's Reasoning
The Court explained that the victims were recruited through false promises of legitimate employment and ultimately exploited for prostitution, and that their status as children at the time of recruitment brought the case within Section 3(a)(2) of Republic Act No. 9208, as amended. Their minority elevated the offense to qualified trafficking under Section 6(a) and 6(c).
On the syndicate qualification, the Court noted that Section 6(c) provides that a syndicate exists when three or more persons act in conspiracy or confederate with one another in carrying out the offense. The records disclosed a coordinated trafficking operation in which each accused-appellant performed a specific role toward a common unlawful objective.
The Court was unpersuaded by the contention that some accused-appellants could not be held liable because they did not personally recruit or transport the victims. It held that once conspiracy is established, the act of one becomes the act of all, so it is immaterial that not all members of the syndicate personally carried out every act.
On penalties, the Court held that the courts below correctly sentenced each accused-appellant to life imprisonment and a fine of PHP 2 million in accordance with Section 10(c). It also ordered the accused-appellants to jointly and severally pay each victim PHP 500,000.00 as moral damages and PHP 100,000.00 as exemplary damages, with 6% legal interest per annum from finality until fully paid.
Source: Supreme Court Decision, G.R. No. 281201.
This report summarizes a public Supreme Court decision and is not legal advice.