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ANTONIO PLANTERAS v. PEOPLE

FACTS:

Petitioner Antonio Planteras, Jr. was convicted for violation of Section 5, par. (a) of Republic Act No. 9208 or promoting trafficking in persons. Reports of alleged trafficking and sexual exploitation at xxxxxxxxxxx Lodge in Cebu City led to a surveillance operation. Pimps were confirmed to be offering the sexual services of young girls at the lodge, which was owned by petitioner and his wife.

In a separate surveillance, an employee of the lodge offered girls for sex to police officers. Petitioner was present at the reception counter during the negotiation. An entrapment operation was conducted, resulting in the arrest of several individuals, including petitioner and his wife, Buhisan, and Tawi.

Petitioner and his wife were accused of knowingly allowing their lodge to be used for promoting trafficking and allowing a minor to engage in prostitution. Buhisan and Tawi were accused of recruiting, transporting, and maintaining females, including a minor, for the purpose of prostitution.

During the trial, testimonies from police officers and a victim, AAA, were presented. AAA testified that she was recruited by Buhisan to work as a prostitute, and petitioner offered her to another customer after providing service to one customer. The prosecution presented evidence of room charges and condoms being sold at the lodge.

The petitioner denied knowing Buhisan and Tawi, and claimed to have been watching television on the night in question. Buhisan testified that she refused the request for female companions but collected payment as instructed by petitioner. Tawi stated that she and Buhisan introduced girls to two police officers who requested it.

The Regional Trial Court (RTC) found petitioner, Buhisan, and Tawi guilty of qualified trafficking in persons and allowing the lodge to be used for promoting trafficking. The Court of Appeals (CA) affirmed their convictions. Petitioner raised various errors relating to the misapprehension of facts, interpretation of the law, insufficiency of evidence, and the presumption of innocence.

In the petition filed before the Supreme Court, the petitioner challenged the decision of the CA. He argued that the evidence against him was not sufficient and questioned the credibility of the prosecution witnesses. The Supreme Court emphasized that only questions of law should be raised in the petition and that it is not a trier of facts. The Court upheld the CA's decision, stating that the factual findings of the appellate courts are final when supported by substantial evidence.

ISSUES:

  1. Whether the conclusions of the lower courts based on circumstantial evidence are correct.

  2. Whether the petitioner should be convicted of promoting trafficking in persons.

  3. Whether circumstantial evidence is sufficient to establish guilt beyond reasonable doubt.

  4. Whether the prosecution has sufficiently established that the accused is guilty of promoting trafficking in persons.

  5. Whether the circumstantial evidence presented by the prosecution proves beyond reasonable doubt that petitioner allowed the use of his establishment in the promotion of trafficking in persons.

  6. Whether the trial court's assessment of the credibility of witnesses and its findings are binding on the reviewing court.

  7. Whether the claim of petitioner that the victim freely engaged in prostitution is a valid defense to the charge of trafficking in persons.

  8. Whether the award of moral and exemplary damages is proper.

RULING:

  1. The Supreme Court affirmed the decision of the lower courts and ruled in favor of the prosecution. The court held that the RTC and the CA correctly convicted the petitioner based on circumstantial evidence and the credibility of the prosecution's witnesses.

  2. Yes, circumstantial evidence is sufficient to establish guilt beyond reasonable doubt. Direct evidence and circumstantial evidence are given equal weight under the Rules of Court. The same standard of proof beyond reasonable doubt applies to both types of evidence. The court must be convinced that the accused is guilty beyond reasonable doubt, whether through direct evidence or inference from proven facts.

  3. Yes, the prosecution has sufficiently established the guilt of the accused. Rule 113, Section 4 of the Rules on Evidence provides three requisites for conviction based on circumstantial evidence: (a) existence of more than one circumstance, (b) proof of the facts from which inferences are derived, and (c) combination of all the circumstances producing a conviction beyond reasonable doubt. In this case, the prosecution presented testimonial, documentary, and object evidence that overwhelmingly proved the elements of promoting trafficking in persons against the accused. The circumstances established an unbroken chain leading to the conclusion that the accused knowingly permitted his establishment to be used for prostitution.

  4. The totality of the circumstantial evidence presented by the prosecution proves beyond reasonable ground that the petitioner allowed the use of his establishment in the promotion of trafficking in persons.

  5. The trial court's assessment of the credibility of witnesses and its findings are accorded high respect and are generally binding on the reviewing court. The factual findings of the trial court are given the highest degree of respect, especially if the appellate court adopts and confirms these, unless facts or circumstances of weight were overlooked, misapprehended, or misinterpreted to materially affect the disposition of the case.

  6. The claim of petitioner that the victim freely engaged in prostitution is unmeritorious. Knowledge or consent of the minor is not a defense under Republic Act No. 9208 (Anti-Trafficking in Persons Act). The victim's consent is rendered meaningless due to the coercive, abusive, or deceptive means employed by perpetrators of human trafficking. Even without the use of coercive, abusive, or deceptive means, a minor's consent is not given out of his or her own free will.

  7. The award of P100,000.00 as moral damages and P50,000.00 as exemplary damages to the victim is proper. This is in accordance with the ruling in People v. Casio, where it was held that the payment of moral and exemplary damages for the crime of trafficking in persons as a prostitute finds basis in Article 2219 of the Civil Code.

PRINCIPLES:

  • The Rules of Court provide that only questions of law should be raised in petitions filed under Rule 45 and that the Supreme Court is not a trier of facts. Factual findings of the appellate courts will not be reviewed or disturbed when supported by substantial evidence.

  • Exceptions to the rule that the Supreme Court does not review factual findings exist, as listed in Medina v. Mayor Asistio, Jr.

  • Direct evidence proves a fact without drawing any inference, while circumstantial evidence indirectly proves a fact in issue, requiring the fact-finder to draw an inference or reason from the evidence presented. The probative value of direct evidence is not necessarily greater than that of circumstantial evidence.

  • Circumstantial evidence is sufficient for conviction if the combination of circumstances is such as to produce a conviction beyond reasonable doubt.

  • The commission of a crime and the identity of the perpetrator may be established by circumstantial evidence.

  • The determination of whether circumstantial evidence is sufficient to support a finding of guilt is a qualitative test, not a quantitative one. The circumstances must be consistent with each other, consistent with the hypothesis of guilt, and inconsistent with every other rational hypothesis except that of guilt.