The recruitment, transportation, transfer, harboring, or receipt of a child for the purpose of exploitation constitutes qualified trafficking in persons, even with the child's consent or knowledge; evidence of the child victim's past sexual conduct or predisposition is inadmissible under the sexual abuse shield rule to discredit the victim or negate the accused's liability.

The case originated from accusations that Adrian Adrales, an adult, engaged in recruiting and facilitating the sexual exploitation of AAA, a 14-year-old minor, by introducing her to different men for sexual intercourse in exchange for money. These incidents allegedly occurred on multiple occasions in July and August 2011, leading to charges of qualified trafficking in persons due to the victim's minority.

• In July 2011, 14-year-old AAA met Adrian Adrales y Jurado (Adrales) while walking home. Adrales invited AAA to the house of his friend, "Emong."
• After eating and watching television, Adrales and Emong left, but only Emong returned and subsequently had sexual intercourse with AAA. Adrales later returned and gave AAA P800.00. This occurred on three separate occasions with Emong, with AAA receiving P800.00 for the first and P700.00 for the subsequent two.
• Enticed by the money, AAA again went with Adrales, this time meeting a man named "Sir" or "Tutor." AAA had sexual intercourse with Sir, and she and her friend Mae received P700.00. This encounter with Sir was allegedly repeated.
• In August 2011, Adrales introduced AAA to another friend, "Hernan." Hernan paid AAA P800.00 for her services and also offered perfume and shoes/slippers. The sexual encounter with Hernan was also repeated.
• Adrales was present before, during (waiting outside or nearby), and after these sexual encounters, and facilitated the payments to AAA.
• AAA's minority (born December 2, 1996, making her 14 at the time of the incidents) was established by her Birth Certificate.
• The incidents came to light after Raquel Constantino, Hernan's wife, discovered her husband's infidelity with AAA, leading to a confrontation and AAA reporting the events to her family.
• A warrant of arrest issued for Adrales on January 25, 2012, indicated he could not be located, leading to an alias warrant and the archiving of the case until his arrest.

• Adrales denied the charges, claiming it was AAA who knew Emong, Sir, and Hernan, and that AAA and Hernan were in a relationship.
• Adrales asserted he only realized AAA was engaged in prostitution after frequently hanging out with her and had nothing to do with it, as AAA was allegedly known as a "pokpok" or "pila-balde" (woman of ill-repute).
• Adrales claimed he dissociated himself from AAA after rumors spread that he was her pimp and was surprised by his arrest after an alleged agreement with AAA's sister for him to no longer communicate with AAA in exchange for withdrawal of the trafficking complaint.
• Adrales argued that the prosecution failed to prove all elements of the crime, particularly that he committed the acts for the purpose of exploiting or prostituting AAA.
• Adrales insisted that AAA engaged in sex with customers without coercion or influence from anyone and that he never received any payment or commission, only accompanying AAA for free drinks and food.
• Adrales contended his right to be presumed innocent should prevail over flimsy and insufficient prosecution evidence, and that not all denials should be seen as fabricated.

• The People of the Philippines, through the Office of the Solicitor General (OSG), argued that Adrales's culpability was proven beyond reasonable doubt.
• The OSG maintained that evidence clearly showed AAA, a child, was recruited, solicited, and pimped by Adrales for sexual intercourse and exploitation with several male customers.
• The OSG asserted that Adrales took advantage of AAA's vulnerability as a child by enticing her with money and material things (perfume, shoes/slippers).
• The OSG stressed that Adrales acted as AAA's recruiter and manager by sending text messages for bookings, setting up meetings, accompanying AAA to the locations, and giving money to AAA after the sexual acts.
• The OSG argued that Adrales's denial cannot prevail over AAA's clear, categorical, and positive testimony.
• The OSG emphasized that the factual findings of the trial court, especially on witness credibility, are generally given full weight and utmost respect on appeal, and that the victim's knowledge or consent is not a defense in trafficking cases involving a minor.

• Whether the Court of Appeals erred in affirming Adrales's conviction for three counts of qualified trafficking in persons under Section 4(a) in relation to Section 6(a) of Republic Act No. 9208.
• Whether Adrales's defense, including his denial and claim that AAA was a willing prostitute, is sufficient to overturn his conviction.
• Whether evidence of AAA's alleged past sexual conduct or reputation is admissible and relevant to determine Adrales's guilt.

• The Supreme Court affirmed the Court of Appeals' Decision, finding Adrales guilty beyond reasonable doubt of three counts of qualified trafficking in persons.
• The Court found that the prosecution successfully established all elements of trafficking in persons under Section 4(a) of RA 9208: (a) the act of recruitment, transportation, and transfer of AAA; (b) by Adrales taking advantage of AAA's vulnerability as a minor; (c) for the purpose of exploitation, specifically prostitution. The crime was qualified under Section 6(a) because AAA was a child at the time of the offenses.
• AAA's testimony was deemed direct, straightforward, consistent, and credible in narrating how Adrales befriended her, recruited her, transported her to meet men, and facilitated payments for sexual services. Adrales's presence before, during, and after the sexual encounters was noted by both lower courts.
• Adrales's defense of denial was considered intrinsically weak and self-serving, unable to outweigh AAA's positive and categorical testimony, especially since it remained unsubstantiated by clear and convincing evidence.
• The Court upheld the application of the sexual abuse shield rule under Section 30(a) of the Rule on Examination of a Child Witness, rendering inadmissible Adrales's testimony that AAA was a "pokpok" or "pila-balde." Such evidence, aimed at proving the victim engaged in other sexual behavior or had a sexual predisposition, is barred.
• Even if AAA had consented or was allegedly a prostitute, Adrales would still be criminally liable, as Section 3(a) of RA 9208 states that trafficking of a child for exploitation is committed even without the involvement of means like threat, force, or coercion, and even with the victim's consent or knowledge.
• Adrales's unexplained flight when a warrant of arrest was issued against him was considered an indication of guilt.
• The penalties imposed (three counts of life imprisonment and a fine of P2,000,000.00 per count) and the damages awarded (P500,000.00 moral damages and P100,000.00 exemplary damages per count, with 6% interest) were found to be in accordance with law and jurisprudence.

• Trafficking in Persons (Elements) — Republic Act No. 9208, Section 3(a) defines trafficking in persons as the recruitment, transportation, transfer, harboring, or receipt of persons, with or without the victim's consent or knowledge, by certain means (threat, force, coercion, deception, abuse of power/vulnerability, etc.) for the purpose of exploitation. Section 4(a) specifically criminalizes recruiting, transporting, transferring, harboring, providing, or receiving a person for prostitution, pornography, sexual exploitation, etc. The Court found all these elements present: Adrales recruited and transported AAA (a minor, thus vulnerable) for sexual exploitation.
• Qualified Trafficking in Persons — Republic Act No. 9208, Section 6(a) provides that trafficking is qualified when the trafficked person is a child. The Court affirmed the qualified nature of the offense as AAA was 14 years old at the time of the incidents.
• Irrelevance of Victim's Consent or Knowledge in Child Trafficking — Republic Act No. 9208, Section 3(a) explicitly states that the recruitment, transportation, transfer, harboring or receipt of a child for the purpose of exploitation shall be considered 'trafficking in persons' even if it does not involve any of the means (like coercion, fraud, etc.) set forth in the preceding paragraph. The Court reiterated that the victim's consent or knowledge, especially a minor's, does not negate the crime.
• Credibility of Witness Testimony — Factual findings of trial courts, including assessment of witness credibility, are accorded great weight and respect, especially when affirmed by the Court of Appeals, as trial courts have the unique opportunity to observe witness demeanor. The Court found AAA's testimony credible.
• Weakness of Denial as a Defense — Denial is an intrinsically weak defense that cannot outweigh positive and categorical testimony, especially when unsubstantiated. Adrales's denial was deemed self-serving and insufficient.
• Sexual Abuse Shield Rule — Section 30(a) of A.M. No. 00-4-07-SC (Rule on Examination of a Child Witness) makes inadmissible evidence offered to prove an alleged child victim engaged in other sexual behavior or had a sexual predisposition. The Court applied this rule to bar Adrales's claims about AAA being a "pokpok," stating such evidence is irrelevant and immaterial to his culpability.
• Flight as an Indication of Guilt — The unexplained flight of an accused may be taken as evidence tending to establish guilt. Adrales's unavailability when the initial warrant of arrest was issued was noted by the Court.
• Moral and Exemplary Damages in Trafficking Cases — Moral damages are awarded for physical suffering, mental anguish, and similar injuries, while exemplary damages are imposed for public good or correction. The Court affirmed the award of P500,000 moral damages and P100,000 exemplary damages per count, citing jurisprudence that trafficking is analogous to, or worse than, seduction, abduction, or rape for purposes of awarding damages under Article 2219 of the Civil Code.

• "The recruitment, transportation, transfer, harboring or receipt of a child for the purpose of exploitation shall also be considered as ‘trafficking in persons’ even if it does not involve any of the means set forth in the preceding paragraph." (Quoting Section 3(a) of RA 9208)
• "Verily, the issue of credibility, when it is decisive of the guilt or innocence of the accused, is determined by the conformity of the conflicting claims and recollections of the witnesses to common experience and to the observation of mankind as probable under the circumstances. It has been appropriately emphasized that '[w]e have no test of the truth of human testimony, except its conformity to our knowledge, observation, and experience. Whatever is repugnant to these belongs to the miraculous and is outside of judicial cognizance.'" (Citing Medina, Jr. v. People of the Philippines)
• "The criminal case of Trafficking in Persons as a Prostitute is an analogous case to the crimes of seduction, abduction, rape, or other lascivious acts. In fact, it is worse." (Citing People v. Lalli)

• People v. Estonilo — Cited for the definition and elements of Trafficking in Persons under RA 9208.
• People v. XXX and YYY — Cited in conjunction with Estonilo for the definition of trafficking.
• People v. Amurao — Cited for the definition of trafficking and for the principle that factual findings of the trial court on credibility are given weight; also cited for the applicability of damages awarded in Lalli to qualified trafficking cases.
• People v. Casio — Cited for the definition of trafficking and that the victim's consent or knowledge (if a minor) is not a defense; also cited for the applicability of damages awarded in Lalli.
• People v. Hirang — Cited for the elements of trafficking and for the basis of awarding moral and exemplary damages, which in turn cited People v. Lalli.
• People v. Moreno — Cited for the principle that a categorical statement with earmarks of truth prevails over a bare denial.
• People v. Bensig — Cited for the principle that denial merits no weight against credible affirmative testimony.
• Medina, Jr. v. People of the Philippines — Cited for the test of credibility based on conformity to common experience and human observation.
• People v. Lalli — A landmark case cited extensively for the principle that trafficking is analogous to or worse than crimes like rape for purposes of awarding damages, and that flight can indicate guilt. The damages awarded in Lalli were applied in this case.
• People of the Philippines v. Camat — Cited for the definition of flight in criminal law and its implication as evidence of guilt.
• People v. XXX (G.R. No. 248815, March 23, 2022) — Cited as a more recent case applying the Lalli ruling on damages in qualified trafficking cases.
• Lara's Gifts & Decors, Inc. v. Midtown Industrial Sales, Inc. — Cited for the application of legal interest on damages.

• Republic Act No. 9208 (Anti-Trafficking in Persons Act of 2003)
  • Section 3(a) — Definition of "Trafficking in Persons," including the provision that for child victims, the means (force, coercion, etc.) need not be present and consent is immaterial. Applied to establish the fundamental nature of the crime and Adrales's liability despite any alleged consent from AAA.
  • Section 4(a) — Enumerates acts constituting trafficking, specifically recruiting, transporting, etc., a person for prostitution or sexual exploitation. Applied as the specific provision Adrales violated.
  • Section 6(a) — Qualifies trafficking when the victim is a child. Applied because AAA was 14 years old.
  • Section 10(c) (now Section 10(e) as amended by RA 10364) — Prescribes the penalty for qualified trafficking (life imprisonment and fine of P2M-P5M). Applied to affirm the penalty imposed on Adrales.
• Republic Act No. 10364 (Expanded Anti-Trafficking in Persons Act of 2012)
  • Section 12 — Amends Section 10 of RA 9208, retaining the penalty for qualified trafficking under 10(e). Referenced to confirm the penalty remains applicable.
• A.M. No. 00-4-07-SC (Rule on Examination of a Child Witness)
  • Section 30(a) (Sexual Abuse Shield Rule) — Prohibits admission of evidence of an alleged child victim's other sexual behavior or sexual predisposition. Applied to exclude Adrales's defense that AAA was a "pokpok."
• Republic Act No. 8505 (Rape Victim Assistance and Protection Act)
  • Section 6 (Rape Shield Rule) — Mentioned as a precursor/variation to the sexual abuse shield rule, prohibiting evidence of a rape complainant's past sexual conduct unless material and relevant.
• Federal Rules of Evidence (United States)
  • Rule 412(a) — Cited as a counterpart to the local sexual abuse shield rule, prohibiting evidence of a victim's sexual behavior or predisposition in sex-offense cases.
• Civil Code of the Philippines
  • Article 2217 — Defines moral damages. Applied as basis for awarding moral damages to AAA.
  • Article 2219 — Enumerates cases where moral damages may be recovered, including "(3) Seduction, abduction, rape, or other lascivious acts," which the Court found analogous to trafficking. Applied to justify moral damages.
  • Article 2229 — Defines exemplary or corrective damages. Applied as basis for awarding exemplary damages.
  • Article 2230 — Allows imposition of exemplary damages in criminal offenses with aggravating circumstances. Applied to justify exemplary damages.