FACTS
The accused was charged with Qualified Trafficking in Persons under Section 4(e), in relation to Section 6(a) of Republic Act (R.A.) No. 9208 (Anti-Trafficking in Persons Act of 2003), as amended by R.A. No. 10364 (Expanded Anti-Trafficking in Persons Act of 2012). The case stemmed from information provided by the Australian Federal Police to the Philippine National Police-Women and Children Protection Center (PNP-WCPC) that a Filipino man was trafficking a 10-year-old girl (AAA) for sexual exploitation through online transactions. Acting on the intelligence report, the PNP conducted an undercover entrapment operation. The accused, using an email account and mobile phone, negotiated with an undercover officer posing as a customer, offering the child for sexual services in exchange for ₱20,000. During the operation at SM Megamall, the accused introduced AAA, described the sexual acts she could perform, accepted the marked money, and was immediately arrested.
At trial, AAA testified that the accused, who was her uncle, had repeatedly forced her to perform sexual acts on foreign men since she was five or six years old and threatened to abuse her younger cousin if she refused. She further narrated that the accused also sexually abused her and recorded the acts. The RTC found the accused guilty beyond reasonable doubt and sentenced him to life imprisonment, a ₱2,000,000 fine, ₱500,000 moral damages, and ₱100,000 exemplary damages. The Court of Appeals affirmed the conviction, holding that all the elements of qualified trafficking in persons had been established by the prosecution through the testimonies of the police officers and the child victim.
ISSUE
Whether the prosecution proved beyond reasonable doubt that the accused committed Qualified Trafficking in Persons under Section 4(e), in relation to Section 6(a) of R.A. No. 9208, as amended by R.A. No. 10364, by maintaining, harboring, and offering a minor for prostitution and sexual exploitation. Specifically, whether the evidence sufficiently established the essential elements of trafficking, namely: (1) the prohibited act of recruiting, maintaining, harboring, or offering a person; (2) the use of coercion, abuse of vulnerability, or other unlawful means; and (3) the purpose of sexual exploitation.
Whether the accused's defenses of denial and innocent explanation regarding the meeting with the undercover agents could overcome the positive identification and credible testimony of the child victim and the law enforcement officers, particularly in light of the constitutional policy of protecting children under the parens patriae doctrine and the State's obligation to suppress trafficking and child sexual exploitation under R.A. No. 9208, as expanded by R.A. No. 10364.
HELD
The Supreme Court denied the appeal and affirmed the conviction of the accused for Qualified Trafficking in Persons. It held that the prosecution successfully established all the elements of the offense under Section 4(e) in relation to Section 6(a) of R.A. No. 9208, as amended by R.A. No. 10364. The evidence clearly showed that the accused maintained, harbored, and offered his 10-year-old niece for sexual exploitation, negotiated the transaction with the undercover officer, accepted the marked money, and intended to deliver the child for prostitution. The offense was qualified because the victim was a minor, a circumstance expressly recognized under Section 6(a), which imposes the penalty of life imprisonment and the corresponding fine. The Court gave full credence to AAA's testimony, emphasizing that the testimony of a child victim of sexual abuse, when credible and consistent, deserves great weight because no young child would fabricate such accusations absent improper motive.
The Court further ruled that the accused's denial and alternative explanation failed to overcome the positive and consistent evidence presented by the prosecution. It reiterated that R.A. No. 9208, as strengthened by R.A. No. 10364, criminalizes not only the actual sexual exploitation of children but also the offering, maintaining, harboring, and facilitating of minors for such purposes. Invoking the parens patriae doctrine, the Court stressed that the State has the highest duty to protect children from abuse, trafficking, and exploitation. Accordingly, the conviction, the penalty of life imprisonment, the ₱2,000,000 fine, and the awards of moral and exemplary damages with legal interest were all affirmed
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