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PEOPLE v. RANIE ESTONILO Y DE GUZMAN

FACTS:

Accused-appellant Ranie Estonilo was charged with two counts of Qualified Trafficking in Persons under Section 4, in relation to Section 6(a) of the Anti-Trafficking in Persons Act of 2003. The prosecution claimed that Estonilo approached two minors, AAA and BBB, and coerced them into engaging in sexual acts with each other in exchange for money. The alleged incidents occurred between March 6, 2010 and March 13, 2010. Estonilo denied knowing AAA and BBB personally and asserted that he was busy with his job during weekdays and his carinderia on weekends. The Regional Trial Court (RTC) found Estonilo guilty of two counts of Qualified Trafficking in Persons and sentenced him to life imprisonment and a fine of P2,000,000.00 for each count. The RTC based its ruling on the clear and categorical testimonies of AAA and BBB. Estonilo appealed to the Court of Appeals (CA), which modified the RTC ruling and found him guilty of two counts of violation of Section 5(a)(5), Article III of the Special Protection of Children Against Abuse, Exploitation, and Discrimination Act. The CA held that Estonilo's acts constituted a violation of RA 7610, rather than Qualified Trafficking in Persons. Estonilo challenged the CA decision before the Supreme Court.

ISSUES:

  1. Whether or not Estonilo should be held criminally liable for his supposed acts against AAA and BBB.

RULING:

  1. Yes, Estonilo should be held criminally liable for his acts against AAA and BBB. The Court affirmed with modification the decision of the CA, finding Estonilo guilty beyond reasonable doubt of two counts of violation of Section 5(a)(5), Article III of RA 7610. The CA held that while Estonilo could not be held criminally liable for Qualified Trafficking in Persons, his acts of offering money and imposing his will on the victims constitute a violation of Section 5 (a)(5), Article III of RA 7610.

PRINCIPLES:

  • Coercion and offering of monetary consideration for sexual acts may constitute a violation of Section 5(a)(5), Article III of RA 7610 even if not considered as "qualified trafficking in persons."

  • Variance doctrine as enunciated in Sections 4 and 5, Rule 120 of the Revised Rules of Criminal Procedure applies when there is a variance of the offense charged and the offense proved.