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PEOPLE v. SHIRLEY A. CASIO

FACTS:

Accused Shirley A. Casio was charged for the violation of Republic Act No. 9208, for hiring and/or recruiting two minors for prostitution and sexual exploitation. The International Justice Mission (IJM), a non-governmental organization, coordinated with the police to entrap persons engaged in human trafficking in Cebu City. The police team rented Rooms 24 and 25 at Queensland Motel, with Room 24 designated for the transaction. Accused noticed two police officers and called their attention, returning with the two minors. The accused assured the officers of the girls' services and cost. The officers convinced accused to come with them to Queensland Motel and handed her marked money. The rest of the police team proceeded to Room 24, arrested accused, informed her of her rights, and confiscated the marked money. AAA testified that she was introduced to prostitution by her friend and accused acted as their pimp. The police rushed into the room and instructed the minors to go to the other room where they were later informed about being rescued.

The accused was found guilty of trafficking in persons under Republic Act No. 9208 and sentenced to twenty years of imprisonment and a fine of one million pesos. The Court of Appeals affirmed the findings of the trial court but modified the fine and awarded moral damages. The accused filed a notice of appeal, raising the issue of whether the prosecution proved guilt beyond reasonable doubt. The Office of the Solicitor General argued for the affirmation of the trial court's decision based on the identification of the accused as the person who solicited customers and received money.

The Philippines signed the United Nations Trafficking Protocol, ratified by the Philippine Senate, which defined human trafficking and recognized the need for an anti-trafficking law in the country. In response, Republic Act No. 9208 was enacted to comprehensively address the issue of human trafficking.

ISSUES:

  1. Whether the entrapment operation conducted by the police was valid, considering that there was no prior surveillance and the police did not know the subject of the operation.

  2. Whether the prosecution was able to prove accused's guilt beyond reasonable doubt even though there was no evidence presented to show that accused has a history of engaging in human trafficking.

  3. Whether accused was properly convicted of trafficking in persons, considering that AAA admitted that she works as a prostitute.

RULING:

  1. Validity of Entrapment Operation The entrapment operation was valid. The court found that accused initiated the transaction, showing predisposition to commit the offense. Lack of prior surveillance does not invalidate the operation. The court emphasized the flexibility needed in police operations to rescue victims.

  2. Proof of Guilt Beyond Reasonable Doubt The prosecution proved accused's guilt beyond reasonable doubt. Accused's initiation of the transaction and her actions during the operation were sufficient evidence. The lack of a prior history of trafficking does not exonerate her.

  3. Consent of Victim Irrelevant Consent or predisposition of the minor (AAA) is irrelevant under Republic Act No. 9208. Trafficking can be committed even with the victim's consent.

PRINCIPLES:

  1. Entrapment vs. Instigation Entrapment is valid as long as the criminal intent originates from the accused. Lack of prior surveillance does not necessarily invalidate the operation.

  2. Trafficking Definition (Republic Act No. 9208) Trafficking includes recruitment, transport, transfer, or receipt of persons by means of coercion or deception for exploitation. Consent of the victim is irrelevant, especially for minors.

  3. Qualified Trafficking The crime is qualified when the trafficked person is a child (below 18 years of age). Special circumstances, such as the involvement of minors, enhance penalties.

  4. Penalties and Sanctions (Republic Act No. 9208) Life imprisonment and a fine are imposed for qualified trafficking, especially involving minors.

  5. Award of Damages Moral and exemplary damages can be awarded in trafficking cases, reflecting the severity and impact of the crime on victims.