View full case

PEOPLE v. GLORIA NANGCAS

FACTS:

Accused-appellant Gloria Nangcas recruited four women, including Judith Singane, promising them employment as house helpers with a salary of P1,500 at Camella Homes in Cagayan de Oro City. However, Nangcas brought the women to Marawi City instead and sold them for a higher price. The recruits were forced to work in Marawi without pay. With the help of a neighboring house helper, Judith was able to contact her father and inform him of their situation. Judith's father reported the incident to the police, and they successfully rescued the girls and filed a case against Nangcas. Nangcas claimed that they changed their plans and proceeded to Marawi City due to a change in employer, but denied the accusations of not paying the girls' salaries.

The Regional Trial Court found Nangcas guilty of Qualified Trafficking in Persons. The RTC determined that Nangcas deceived the victims, transported them from one place to another, and left them penniless and forced to work against their will. Nangcas appealed the decision to the Court of Appeals, but the CA affirmed the RTC's ruling, finding that Nangcas had recruited and transported the victims, employed fraud and deceit, and forced them into labor and slavery. Nangcas argues in her appeal that there was no deception or taking advantage of the victims and that there were inconsistencies in the testimonies of the private complainants.

ISSUES:

  1. Whether or not accused-appellant Nangcas is guilty of qualified trafficking in persons under R.A. No. 9208.

  2. Whether or not the elements of trafficking in persons are present in this case.

  3. Whether the prosecution was able to prove the guilt of the accused beyond reasonable doubt for the offense of trafficking in persons under R.A. No. 9208.

  4. Whether the victims were sold for forced labor, slavery, or involuntary servitude.

  5. Whether the alleged inconsistencies in the testimonies of the witnesses affect their credibility and the conviction of the accused.

  6. Whether or not the respondent committed gross misconduct in violation of the Code of Conduct and Ethical Standards for Public Officials and Employees.

  7. Whether or not the respondent should be administratively sanctioned for his misconduct.

RULING:

  1. The court affirms accused-appellant Nangcas' conviction for qualified trafficking in persons under R.A. No. 9208.

  2. The presence of the elements of trafficking in persons was established by the prosecution witnesses, namely the victims and their parents. The testimonies showed that Nangcas employed deception and fraud in recruiting and transporting the victims for forced labor or services in Marawi City.

  3. The prosecution has proven the guilt of the accused beyond reasonable doubt for the offense of trafficking in persons under R.A. No. 9208. The accused employed fraud and deception to bring the victims to Marawi City, and her intention to deceive was evident from her false representations to the victims and their parents about the nature and location of the work. The acts of the accused constitute deceit and fraud as defined by law.

  4. The victims were sold for forced labor as they were enticed to work as house helpers under false pretenses and were brought to a different place without their consent. They were constrained to work without pay and were unable to leave their work because they were told that their salary had already been given to the accused.

  5. The alleged inconsistencies in the testimonies of the witnesses are minor and do not affect their credibility. These inconsistencies pertain to minor details and do not negate the unlawful activity and violation of R.A. No. 9208 committed by the accused. The factual findings of the trial court and its assessment of the witnesses' credibility are accorded the highest respect and will not be disturbed on appeal.

  6. Yes, the respondent committed gross misconduct in violation of the Code of Conduct and Ethical Standards for Public Officials and Employees.

  7. Yes, the respondent should be administratively sanctioned for his misconduct.

PRINCIPLES:

  • The elements of trafficking in persons under R.A. No. 9208 include recruitment, transportation, transfer, or harboring of persons with or without their consent or knowledge, through various means of coercion, for the purpose of exploitation such as forced labor or services, slavery, servitude, or the removal or sale of organs.

  • Qualified trafficking in persons includes cases where the crime is committed against a child, or by a syndicate or in large scale.

  • Deception and fraud may be used by the trafficker to gain the trust and confidence of the victims and their parents, thereby ensuring their compliance and exploitation.

  • Deceit is the false representation of a matter of fact that deceives another so that they shall act upon it to their legal injury, while fraud is every kind of deception for the purpose of leading another party into error. (Definition of deceit and fraud)

  • Slavery is defined as the extraction of work or services from any person by means of enticement, violence, intimidation, or threat, including deprivation of freedom, abuse of authority or moral ascendancy, debt bondage, or deception. (Definition of slavery)

  • The factual findings of the trial court, its assessment of witness credibility, and the probative weight of their testimonies are entitled to the highest respect on appeal. The court will not re-evaluate the evidence already passed upon by the trial court and affirmed by the appellate court.

  • The Code of Conduct and Ethical Standards for Public Officials and Employees sets the standards of behavior expected from government employees.

  • Gross misconduct refers to the violation of the Code of Conduct and Ethical Standards for Public Officials and Employees that is characterized by a flagrant disregard of established rules.

  • Administrative sanctions may be imposed upon government employees found guilty of gross misconduct.