People vs. Villaria and Maghirang

The recruitment, transportation, and provision of minors for the purpose of prostitution constitutes qualified trafficking in persons under Republic Act No. 9208, as amended, even when the means employed do not involve force, threat, coercion, or deception. The qualifying circumstance of minority is sufficient to elevate the crime, and the corroborating testimonies of the victims and the arresting officer are sufficient to sustain a conviction.

Jhona Galeseo Villaria and Lourdes Aralar Maghirang were charged with eight counts of qualified trafficking in persons for recruiting and transporting eight minor girls to a resort in Rizal to offer them for prostitution to police officers posing as customers. The operation was based on information from a confidential informant, leading to an entrapment operation on March 18, 2016, where the accused were arrested after accepting marked money.

• The Entrapment Operation: On March 14, 2016, Police Inspector Magno Abana, Jr. (PINSP Abana) received information about trafficking activities at a resort in Rizal. A surveillance team was formed. On March 15, 2016, the team met the accused at the resort. Maghirang offered lady companions aged 14-18 for sex at specified prices. An entrapment operation was planned for March 18, 2016.
• The Arrest: On March 18, 2016, PINSP Abana and other officers went to the resort with marked money. Maghirang and Villaria arrived with several minor girls. After the accused accepted the marked money and asked for the balance, the police arrested them. The girls were taken into custody by the Department of Social Welfare and Development.
• Victims' Testimonies: All eight minor victims (AAA259133 to HHH259133) testified that the accused recruited or cajoled them to go to the resort to prostitute themselves in exchange for money. One victim stated she agreed because she needed money.
• Defense's Version: The accused denied the charges. They claimed they were at the resort for a birthday party when they were forced to accept ₱30,000.00. A defense witness, Judilyn Lastrilla, corroborated their story but admitted authorities told her to implicate the accused.

• Failure to Prove Means: Petitioners argued the prosecution failed to prove the victims were forced, coerced, or deceived into prostitution.
• Credibility of Testimony: Petitioners contended the victims' testimonies were not voluntarily given and were under duress or undue influence.
• Failure to Present Corpus Delicti: Petitioners maintained the prosecution failed to prove they received money because the marked bills or photographs thereof were not presented in evidence.

• Elements Proven: The People countered that all elements of qualified trafficking were established through the victims' and the police officer's testimonies.
• Immateriality of Means: The People argued that because the victims were minors, the means employed (force, coercion, etc.) were irrelevant to the crime.
• Sufficiency of Testimonial Evidence: The People maintained the corroborating testimonies of the victims and the arresting officer were sufficient for conviction, and the non-presentation of the marked money was not fatal.

• Sufficiency of Evidence: Whether the prosecution proved the accused-appellants' guilt beyond reasonable doubt for qualified trafficking in persons.
• Materiality of Means: Whether the absence of proof of force, threat, coercion, or deception is fatal to the charge when the victims are minors.
• Evidentiary Weight: Whether the non-presentation of the marked money and photographs thereof invalidates the prosecution's case.

• Sufficiency of Evidence: The prosecution proved guilt beyond reasonable doubt. The consistent and corroborated testimonies of the eight minor victims and PINSP Abana established that the accused recruited, transported, and offered the minors for prostitution.
• Materiality of Means: The absence of proof of force, threat, or coercion is immaterial. Under the law, the recruitment, transportation, or receipt of a child for exploitation constitutes trafficking even if the means are not those enumerated in the statute. The accused took advantage of the victims' youth and need for money.
• Evidentiary Weight: The non-presentation of the marked money is not fatal. The testimony of the arresting officer, who caught the accused in flagrante delicto, sufficiently corroborated the victims' accounts and proved the accused counted the money received as payment.

• Trafficking of Children — Under Section 3(a) of Republic Act No. 9208, as amended, the recruitment, transportation, transfer, harboring, or receipt of a child for the purpose of exploitation constitutes trafficking in persons even if the means employed (e.g., force, coercion, deception) are not used. The qualifying circumstance of the victim's minority is sufficient.
• Sufficiency of Corroborating Testimony — The corroborating testimonies of the minor victim and the arresting officer who conducted an entrapment operation are sufficient to sustain a conviction for trafficking in persons, even without the presentation of the marked money used in the operation.

• "There is trafficking in persons if the victim is a child even when the means employed are different from those set forth in the law."
• "The absence of threat, force, or coercion is immaterial and irrelevant. Under Section 3(a) of Republic Act No. 9208, as amended, the crime is still considered trafficking if it involves '[t]he recruitment, transportation, transfer, harboring[,] or receipt of a child for the purpose of exploitation' even if the means employed is not within those set forth in the law."
• "The testimony of PINSP Abana who conducted the entrapment operation is accorded full faith and credence absent any clear and convincing evidence that the police officers did not properly perform their duties or that they were prompted by ill motive."

• People v. Casio, 749 Phil. 458 (2014) — Cited for the elements of trafficking in persons as derived from the definition in Republic Act No. 9208, as amended.
• People v. Ramirez, 846 Phil. 314 (2019) — Cited for the principle that the crime is still trafficking when it involves a child for exploitation, regardless of the means employed, and for the amount of moral damages awarded.
• People v. Barte, 806 Phil. 533 (2017) and People v. Resurreccion, 711 Phil. 135 (2013) — Cited for the rule that the testimony of an arresting officer is accorded full faith in the absence of proof of improper performance of duty or ill motive.
• People v. Kelley, 874 Phil. 906 (2020) — Cited for the principle that the assessment of witness credibility is best left to the trial court.

• Section 3(a), Republic Act No. 9208 (2003), as amended by Republic Act No. 10364 (2013) — Defines trafficking in persons, including the act, means, and purpose. The Court relied on this provision to establish the elements of the crime and to rule that the means are immaterial when the victim is a child.
• Section 4(a) in relation to Sections 6(a) and 6(c), Republic Act No. 9208, as amended — The specific provisions under which the accused were charged, penalizing qualified trafficking where the victim is a child.

• Justice Alfredo Benjamin S. Caguioa
• Justice Jhosep Y. Lopez
• Justice Mario V. Lopez
• Justice Antonio T. Kho, Jr.