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PEOPLE v. JEHLSON AGUIRRE Y ARIDIDON

FACTS:

Accused-appellants Jehlson Aguirre, Michael Arabit, Jefferson Paralejas, and Jeffrey Roxas were charged with Qualified Trafficking in Persons under Republic Act No. 9208 or the Anti-Trafficking in Persons Act of 2003, in relation to violation of Republic Act No. 7610 or the Special Protection of Children Against Abuse, Exploitation, and Discrimination Act. They were accused of recruiting, transporting, harboring, providing, or receiving, in conspiracy with one another, ten girls, including seven minors, for purposes of prostitution and sexual exploitation.

Four of the girls testified in court against the accused-appellants, narrating how they were convinced by them to engage in sexual activities with foreigners in exchange for money and shabu. The accused-appellants were arrested after the police received information from a civilian informant that they would be bringing ten women to an apartment in Quezon City to be distributed as prostitutes. The police arrested the accused-appellants and referred the girls to social workers. Despite the appellants' denial of the charges, they were convicted by the Regional Trial Court (RTC) of Quezon City and sentenced to life imprisonment and a fine of P2 million each. The accused-appellants appealed the decision to the Court of Appeals (CA), arguing that their guilt was not proven beyond reasonable doubt. The CA affirmed the RTC's judgment but made modifications to the monetary awards and imposed interest on the total amount.

ISSUES:

  1. Whether the trial court's factual findings and conclusions, affirmed by the Court of Appeals, should be overturned.

  2. Whether the elements of trafficking in persons have been satisfactorily established by the prosecution.

  3. Whether accused-appellants took advantage of the youth and vulnerability of private complainants.

  4. Whether private complainants' consent is relevant in determining the crime of trafficking in persons.

  5. Whether there is conspiracy among accused-appellants.

  6. Whether the testimony of what one heard a party say is hearsay.

  7. Whether the testimonies of the private complainants are credible and solid.

  8. Whether the minority of the victims is a qualifying circumstance for the crime of trafficking in persons.

RULING:

  1. The Court finds no reason to overturn the factual findings and conclusions of the trial court and the Court of Appeals as to the guilt of accused-appellants. The trial court's factual findings, including its assessment of credibility and probative weight of testimonies, are accorded great respect and even conclusive effect on appellate review, provided there are no glaring errors in the factual findings.

  2. The prosecution has satisfactorily established the elements of trafficking in persons under Section 3(a) of RA 9208, which include the act of recruitment, transportation, transfer or harboring of persons, the means used which involve force, coercion, fraud, or abuse of power, and the purpose of exploitation such as prostitution, sexual exploitation, forced labor, slavery, or organ removal or sale.

  3. Accused-appellants took advantage of the youth and vulnerability of private complainants, who were still in their teens at the time of the crime.

  4. Private complainants' consent is not relevant in determining the crime of trafficking in persons, particularly when the victims are minors below 18 years old. Section 3(a) of RA 9208 explicitly states that when the victim is a minor, the recruitment or transportation need not involve coercive, abusive, or deceptive means, as a minor's consent is not given out of their own free will.

  5. Conspiracy among accused-appellants has been established by their concerted action before, during, and after the crime, demonstrating their unity of design and objective to recruit and transport the victims for the purpose of exploitation and offering them for prostitution.

  6. The Court held that testimony of what one heard a party say is not necessarily hearsay. It is admissible in evidence, not to show that the statement was true, but that it was in fact made. If credible, it may form part of the circumstantial evidence necessary to convict the accused.

  7. The Court upheld the trial court's findings that the testimonies of the private complainants were solid and credible. The trial court had the opportunity to examine the demeanor of the private complainants on the witness stand and found their testimonies to be consistent, strong, and corroborative of each other. The trial court's assessment of the credibility of witnesses will not be disturbed on appeal unless there are overlooked, misapprehended, or misinterpreted facts or circumstances of weight that would materially affect the disposition of the case. No such misapprehension or misinterpretation was found in this case.

  8. The minority of the victims is a qualifying circumstance for the crime of trafficking in persons.

PRINCIPLES:

  • The trial court's factual findings, including credibility assessments, are accorded great respect and even conclusive effect on appellate review.

  • The elements of trafficking in persons under Section 3(a) of RA 9208 include the act of recruitment, transportation, transfer or harboring, means used involving force, coercion, fraud, or abuse of power, and the purpose of exploitation.

  • Youth and vulnerability of victims can be considered as factors in determining the intention to exploit in trafficking cases.

  • Consent of victims, especially when they are minors, is not relevant in determining the crime of trafficking in persons.

  • Conspiracy can be established through concerted action before, during, and after the crime, demonstrating a common purpose and community of interest among the accused.

  • Testimony of what one heard a party say is not necessarily hearsay. It is admissible in evidence to show that the statement was made, not that it was true.

  • The trial court is in a better position to assess the credibility of witnesses as it can observe their demeanor, conduct, and attitude under grueling examination. Findings of the trial court on credibility will not be disturbed on appeal unless there are overlooked, misapprehended, or misinterpreted facts or circumstances of weight that would materially affect the disposition of the case.

  • A witness who testifies in a categorical, straightforward, spontaneous, and consistent manner is considered credible.

  • The absence of foreigners in an apartment does not negate the crime of trafficking in persons. The law does not require the presence of clients or the victims to be found in a brothel or prostitution den for the crime to be committed. The act of luring, enticing, or transporting victims for the purpose of exploitation is sufficient.

  • The crime of trafficking in persons is qualified when the trafficked person is a child.

  • The minority of the victims can be appreciated as a qualifying circumstance if sufficiently alleged in the Information and proven.

  • Any person found guilty of qualified trafficking shall suffer the penalty of life imprisonment and a fine of not less than P2 million but not more than P5 million.

  • Subsidiary imprisonment cannot be imposed when the principal penalty imposed is higher than prision correccional.

  • The award of moral damages and exemplary damages is justified in cases of physical injuries, seduction, abduction, rape, or other lascivious acts.

  • Joint and several liability applies to the payment of moral and exemplary damages.

  • Interest can be imposed on the monetary award for damages.