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PEOPLE v. SUSAN SAYO Y REYES

FACTS:

Accused-appellants Susan Sayo and Alfredo Roxas were charged with qualified trafficking in persons under Section 4 (a,e), Section 5 (a), and Section 6 (a) of Republic Act No. 9208. It was alleged that Sayo recruited and transported minors AAA and BBB, as well as CCC who was of legal age, for prostitution. Roxas was accused of managing and operating a room in his apartment for the purpose of prostitution.

On November 15, 2005, a rescue operation was conducted by the Criminal Investigation and Detection Group-Women and Children Complaint Division (CIDG-WCCD) in coordination with the International Justice Mission (IJM) and the DSWD-NCR. Sayo offered AAA and BBB to undercover agents as 15-year-old girls and informed them about the room in Roxas's house. The undercover agents, Sayo, and Roxas discussed the transaction, and when payment was handed over, the raid was announced and the accused-appellants were apprehended.

During the trial, Sayo claimed that she was arrested without her knowledge or consent, while Roxas argued that he was sleeping in his house and was forced to accept the money. The Regional Trial Court (RTC) found the accused guilty beyond reasonable doubt of qualified trafficking in persons.

The accused appealed the decision of the RTC, with the issue being whether the guilt of Roxas was proven beyond reasonable doubt. The Court of Appeals (CA) affirmed the RTC decision with modifications, including the award of damages to the victims. Sayo died during the appeal.

ISSUES:

  1. Whether the death of the accused extinguished her criminal and civil liability.

  2. Whether the affirmed factual findings of the RTC should be respected by the Court.

  3. Whether the conviction of the accused for Qualified Trafficking of Persons and Trafficking in Persons is proper.

  4. Whether the proper offense committed by the accused is Acts that Promote Trafficking in Persons under Section 5(a) of RA 9208 or Qualified Trafficking in Persons under Section 6(a) of RA 9208.

  5. Whether the penalty imposed by the trial court is correct.

  6. Whether Roxas can be held liable for moral and exemplary damages to AAA, BBB, and CCC.

  7. Whether the award of damages should be modified.

RULING:

  1. The death of the accused extinguished both her criminal and civil liability. Article 89, paragraph 1 of the Revised Penal Code provides that criminal liability is totally extinguished by the death of the convict. The civil liability arising from the criminal liability is also extinguished upon the death of the accused, unless it may be predicated on a source of obligation other than delict. In this case, as the death of the accused occurred before final judgment, both her criminal and civil liability were extinguished.

  2. The affirmed factual findings of the RTC should be respected by the Court. It is a well-established doctrine in appellate review that factual findings of the trial court, including its assessment of the credibility of witnesses and probative weight of evidence, are accorded great weight and respect. In this case, the testimonies of the witnesses were corroborative of each other and outweighed the accused's weak defenses of denial and alibi.

  3. The accused should be convicted for Acts that Promote Trafficking in Persons and not for Trafficking in Persons. The courts a quo committed an error in convicting the accused for Qualified Trafficking of Persons and Trafficking in Persons. The offenses proscribed under Section 5 of RA 9208 are properly denominated as Acts that Promote Trafficking in Persons. The offenses of Trafficking in Persons and Acts that Promote Trafficking in Persons are separate and distinct offenses with their own corresponding penalties. The accused should be convicted for Acts that Promote Trafficking in Persons under Section 5(a) of RA 9208.

  4. The Supreme Court held that the proper offense committed by the accused is Acts that Promote Trafficking in Persons under Section 5(a) of RA 9208. The trial court and the Court of Appeals erred in convicting the accused of Qualified Trafficking in Persons and Trafficking in Persons. The clarificatory amendment in RA 10364 expressly states that only violations of Section 4 on Trafficking in Persons can be considered as qualified trafficking. Section 5 on Acts that Promote Trafficking in Persons cannot be qualified because the law does not expressly provide for it. Therefore, the accused's conviction should be corrected to Acts that Promote Trafficking in Persons under Section 5(a) of RA 9208.

  5. The Supreme Court modified the penalty imposed by the trial court. The proper penalty for Acts that Promote Trafficking in Persons is imprisonment of fifteen (15) years and a fine of Five Hundred Thousand Pesos (P500,000.00). The penalty of life imprisonment and a fine of Two Million Pesos (P2,000,000.00) imposed by the trial court is excessive and should be corrected.

  6. Roxas can be held liable for moral and exemplary damages to AAA, BBB, and CCC, even though it was not proven that he directly participated in their prostitution or solicited customers for them. By renting out a room in his house, Roxas promoted and facilitated their prostitution, which is just as deplorable. Thus, he is liable for the damages suffered by the victims.

  7. The award of damages should be modified. While the usual amount of moral and exemplary damages in cases of Trafficking in Persons as a prostitute is P500,000.00 and P100,000.00, respectively, the Court in Planteras, Jr. v. People set the award at P100,000.00 and P50,000.00 in cases of Acts that Promote Trafficking in Persons. Therefore, Roxas is liable to pay moral and exemplary damages to each of the victims in the amount of P100,000.00 and P50,000.00, respectively. The monetary awards shall also earn legal interest of six percent (6%) per annum from the finality of judgment until full payment.

PRINCIPLES: