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PEOPLE v. MITCHELLE VALENCIA Y DIZON

FACTS:

The case involves Valencia and Simbillo who were accused of engaging in the recruitment, obtaining, providing, offering, and maintaining persons for prostitution and sexual exploitation of minors. The charges stemmed from incidents that occurred on May 27, 2014, in Angeles City, Pampanga. The Regional Anti-Trafficking Task Group received a flash drive containing BBC News footage showing Valencia offering the sexual services of minor girls to foreigners along Fields Avenue. With this information, the police conducted surveillance and eventually organized an entrapment operation. On May 26, 2014, a team of police officers was formed to entrap Valencia and Simbillo. PO3 Mendoza, acting as the driver for a foreigner posing as a client, received marked bills for the transaction. At around 6:30 p.m., the team arrived at the target place, where Valencia approached PO3 Mendoza and offered the minors she was with for a certain amount. Simbillo, who was with five minor girls, also offered the services of the minors. When the confidential asset agreed to the payment, Valencia directed the girls to board a van, with Simbillo joining them. At that moment, the police team approached and arrested Valencia and Simbillo, recovering the marked money and rescuing the victims. During the trial, witnesses AAA, BBB, CCC, DDD, EEE, GGG, and HHH testified about their experiences. AAA testified that Simbillo had previously prostituted her and received a commission from her clients. CCC and DDD had similar allegations against Valencia, stating that she had facilitated their sexual exploitation and took a portion of the payment. CCC and DDD further testified that on May 26, 2014, Simbillo and Valencia approached them, offering to take them to eat at Jollibee where a foreigner would talk to them, feed them, and give them money. EEE and GGG had a similar encounter with Simbillo in a nearby park, while Valencia deceived HHH and BBB using the same narrative. The defense denied the charges, claiming that the accused were framed and presenting witnesses to support their claim. Valencia, Simbillo, and Rose E. Carandang testified for the defense. Valencia claimed that a foreigner offered to feed the girls and invited them to have pizza, but they were arrested by police officers when they boarded the foreigner's van.

The defendants, Mitchelle Valencia and Joane Simbillo, were convicted of qualified trafficking in persons in Criminal Case No. 14-11902. It was found that they acted in conspiracy to deceive a minor named CCC into offering her sexual services to a foreign asset. Valencia was also found guilty in Criminal Case No. 14-11903 for obtaining another minor named DDD and engaging her in prostitution. However, the court did not find the minority of the victim HHH proven, even though she gave clear testimony of how Valencia deceived and prostituted her. Valencia was only held liable for trafficking in persons in Criminal Case No. 14-11907. In Criminal Case No. 14-11900, Simbillo was found guilty of trafficking in persons for peddling victim AAA to a foreigner for sexual exploitation. The defendants were acquitted in Criminal Case Nos. 14-11901, 14-11904, 14-11905, and 14-11906 due to failure of the prosecution to prove their guilt beyond reasonable doubt.

The accused, Mitchelle Valencia and Joane Simbillo, were charged with the violation of Section 4(a) in relation to Section 6(a) of Republic Act No. 9208 or Qualified Trafficking in Persons. In Criminal Case No. 14-11906, both defendants were acquitted of the said charge. However, in Criminal Case No. 14-11907, Valencia was found guilty beyond reasonable doubt of the offense of Violation of Section 4(a) of Republic Act No. 9208 or Trafficking in Persons. Valencia was sentenced to imprisonment for twenty (20) years and ordered to pay a fine of One million pesos (P1,000,000.00). Valencia was also ordered to indemnify the private complainant with nominal damages in the amount of fifty thousand pesos (P50,000.00). On the other hand, Simbillo was acquitted of the offense of Violation of Section 4(a) in relation to Section 6(a) of Republic Act No. 9208 or Qualified Trafficking in Persons. The Court of Appeals affirmed the convictions of Valencia and Simbillo, finding that all the elements of trafficking in persons were present and proven.

ISSUES:

  1. Whether the accused-appellants are guilty of violations of the Anti-Trafficking in Persons Act.

  2. Whether accused-appellants committed qualified trafficking in persons in violation of Section 4(a) of the Anti-Trafficking in Persons Act.

  3. Whether the age of the victims was proven during trial.

  4. Whether accused-appellants were lawfully arrested pursuant to an entrapment operation.

  5. Whether the warrantless arrest of accused-appellants was valid in this case.

  6. Whether the arresting officer had personal knowledge of the commission of the offense.

  7. Whether or not the arresting officer needs to act as the poseur-client himself in an entrapment operation.

  8. Whether or not the exact date of the offense needs to be stated in the information.

  9. Whether accused-appellants are guilty beyond reasonable doubt of trafficking in relation to Section 4(a) of Republic Act No. 9208, as amended by Republic Act No. 10364.

  10. Whether accused-appellant Joane Simbillo y Lauretti in Criminal Case No. 14-11900 should be sentenced to suffer the penalty of twenty years of imprisonment and to pay a fine of P1,000,000.00.

  11. Whether accused-appellants Mitchelle Valencia y Dizon and Joane Simbillo y Lauretti in Criminal Case No. 14-11902 should be sentenced to suffer the penalty of life imprisonment and to pay a fine of P2,000,000.00.

  12. Whether accused-appellant Mitchelle Valencia y Dizon in Criminal Case No. 14-11903 should be sentenced to suffer the penalty of life imprisonment and to pay a fine of P2,000,000.00.

  13. Whether accused-appellant Mitchelle Valencia y Dizon in Criminal Case No. 14-11907 should be sentenced to suffer the penalty of twenty years of imprisonment and to pay a fine of P1,000,000.00.

RULING:

  1. The accused-appellants are guilty of violations of the Anti-Trafficking in Persons Act. The Court of Appeals affirmed their conviction for trafficking in persons based on the evidence presented by the prosecution. The court found that all the elements necessary to establish their guilt were proven beyond reasonable doubt. The court also noted that the victims' testimonies were "positive, categorical, and unequivocal" and trumped the accused-appellants' mere denial. The appeal was dismissed and the conviction was sustained.

  2. Accused-appellants are guilty of qualified trafficking in persons. Section 4(a) of the Anti-Trafficking in Persons Act prohibits any person from recruiting, obtaining, hiring, providing, offering, transporting, transferring, maintaining, harboring, or receiving a person by any means, including under the pretext of domestic or overseas employment, for the purpose of prostitution, pornography, or sexual exploitation. In this case, accused-appellants deceived the victims into going with them, promising them a party and money, but their true intention was to exploit the victims sexually. The corroborating testimonies of the arresting officer and the minor victims were sufficient to sustain the conviction.

  3. The age of the victims was proven during trial. The minority of the victims was alleged in the Informations, and the victims themselves testified regarding their ages. The lower courts correctly found accused-appellants guilty of qualified trafficking.

  4. Accused-appellants were lawfully arrested pursuant to an entrapment operation. The arrest was in accordance with the constitutional right of the people to be secure in their persons, houses, papers, and effects against unreasonable searches and seizures. The entrapment operation was conducted to catch accused-appellants in the act of trafficking in persons, and the arrest was made after they were caught in the act of peddling the victims for sexual exploitation.

  5. The warrantless arrest of accused-appellants was valid in this case. The arrest falls under Section 5(a) of Rule 113 of the Revised Rules of Criminal Procedure, which allows a peace officer or a private person to arrest a person without a warrant when the person to be arrested has committed, is actually committing, or is attempting to commit an offense in the presence of the arresting officer. In this case, accused-appellants were arrested in flagrante delicto when they peddled women to the confidential asset who was accompanied by undercover police. The prosecution was able to establish that accused-appellants transacted with the asset to sexually exploit the victims, and the testimonies of the arresting officer and the victims corroborate this.

  6. The arresting officer had personal knowledge of the commission of the offense. The testimony of the arresting officer, PO3 Mendoza, establishes that he was present with the confidential asset during the transaction with accused-appellants. He witnessed the pimps offering the victims for sexual services and heard the transaction details. Accused-appellants' claim that he could not have heard their conversation is unsubstantiated. Therefore, the arresting officer had personal knowledge of the offense.

  7. The Court ruled that there is no requirement that the arresting officer must act as the poseur-client himself in an entrapment operation. In this case, the circumstances called for the officer to take on a more passive role, while a foreign asset acted as the poseur-client. This is not considered irregular and does not invalidate the entrapment operation.

  8. The Court ruled that the exact date of the offense does not need to be stated in the information unless it is a material ingredient of the offense. Rule 110, Section 11 of the Revised Rules of Criminal Procedure allows the offense to be alleged to have been committed on a date as near as possible to the actual date of its commission. In this case, the information sufficiently averred that the offense was committed sometime in February 2014, and this is deemed acceptable.

  9. Accused-appellants are found guilty beyond reasonable doubt of trafficking in relation to Section 4(a) of Republic Act No. 9208, as amended by Republic Act No. 10364.

  10. Accused-appellant Joane Simbillo y Lauretti in Criminal Case No. 14-11900 is sentenced to suffer the penalty of twenty years of imprisonment and to pay a fine of P1,000,000.00.

  11. Accused-appellants Mitchelle Valencia y Dizon and Joane Simbillo y Lauretti in Criminal Case No. 14-11902 are sentenced to suffer the penalty of life imprisonment and to pay a fine of P2,000,000.00.

  12. Accused-appellant Mitchelle Valencia y Dizon in Criminal Case No. 14-11903 is sentenced to suffer the penalty of life imprisonment and to pay a fine of P2,000,000.00.

  13. Accused-appellant Mitchelle Valencia y Dizon in Criminal Case No. 14-11907 is sentenced to suffer the penalty of twenty years of imprisonment and to pay a fine of P1,000,000.00.

PRINCIPLES:

  • The trial court's credibility findings are generally not disturbed on appeal, especially when affirmed by the Court of Appeals.

  • Trafficking in persons is defined as the recruitment, transportation, transfer, or harboring of persons through various means for the purpose of exploitation.

  • Trafficking in persons is illegal and punishable under the Anti-Trafficking in Persons Act. It involves the recruitment, transportation, transfer, or harboring of persons with or without their consent, using various means and for the purpose of exploitation, such as prostitution, pornography, sexual exploitation, forced labor, servitude, or sale of organs.

  • The elements of trafficking in persons include the act of recruitment, obtaining, hiring, providing, offering, transportation, transfer, maintaining, harboring, or receipt of persons; the use of means such as force, coercion, abduction, fraud, deception, abuse of power or position, or the giving or receiving of payments or benefits; and the purpose of exploitation.

  • The crime of trafficking in persons can be qualified if the trafficked person is a child.

  • Corroborating testimonies of the arresting officer and the victims can be sufficient to sustain a conviction for trafficking in persons.

  • The age of the victims must be proven during trial to establish the offense of qualified trafficking in persons.

  • Entrapment operations can be lawfully conducted to catch perpetrators of trafficking in persons.

  • Seizures of whatever nature and for any purpose shall be inviolable, and no search warrant or warrant of arrest shall issue except upon probable cause to be determined personally by the judge after examination under oath or affirmation of the complainant and the witnesses he may produce, and particularly describing the place to be searched and the persons or things to be seized.

  • A warrantless arrest in flagrante delicto is lawful when the person to be arrested has committed, is actually committing, or is attempting to commit an offense in the presence of the arresting officer.

  • Entrapment is conducted to catch the offender in flagrante delicto, while instigation is when the accused is induced to commit the crime.

  • Flexibility is allowed in police operations, including entrapment operations, as long as the rights of the accused have not been violated in the process.

  • Entrapment is sanctioned as a means of arresting offenders who traffic persons.

  • The arresting officer does not need to act as the poseur-client himself in an entrapment operation.

  • The exact date of the offense does not need to be stated in the information unless it is a material ingredient of the offense.

  • Victims of trafficking face profound suffering that may last their lifetime.

  • Monetary awards for damages imposed on traffickers shall be subject to the rate of 6% per annum from the finality of the decision until their full satisfaction.