In People v. Sayo and Roxas, the Supreme Court clarified the distinction between trafficking in persons and acts that promote trafficking under Republic Act No. 9208 (RA 9208). The Court underscored that while renting a room knowingly used for prostitution promotes trafficking, it does not equate to directly engaging in trafficking itself. This distinction carries significant implications for how individuals involved in facilitating prostitution are charged and penalized, ensuring that the punishment aligns more accurately with the nature and extent of their involvement.

The Landlord’s Liability: When Renting a Room Becomes Promoting Trafficking

The case originated from an entrapment operation where Susan Sayo was caught recruiting minors for prostitution, and Alfredo Roxas was found to be operating a room in his apartment as a prostitution den. Both were initially convicted of qualified trafficking in persons. The key issue before the Supreme Court was whether Roxas’s actions constituted trafficking in persons or merely acts that promote trafficking, which carries a lesser penalty.

The Supreme Court meticulously reviewed the facts and legal arguments, emphasizing the importance of accurately distinguishing between the offenses under RA 9208. The Court acknowledged the factual findings of the lower courts, which established that Roxas knowingly leased a room in his house for the purpose of prostitution. However, it diverged in its legal conclusion, pointing out that the Regional Trial Court (RTC) and the Court of Appeals (CA) erred in convicting Roxas of qualified trafficking of persons. According to the Supreme Court, his actions fell more appropriately under Section 5(a) of RA 9208, which pertains to Acts that Promote Trafficking in Persons.

The Court highlighted the distinct nature of the offenses under RA 9208, explaining that Section 4 addresses direct acts of trafficking, such as recruiting, transporting, or harboring individuals for exploitation. In contrast, Section 5 targets acts that facilitate or promote trafficking, such as knowingly leasing property for such purposes. The Supreme Court quoted the relevant provisions of RA 9208 to illustrate the distinction:

SEC. 4. Acts of Trafficking in Persons. — It shall be unlawful for any person, natural or juridical, to commit any of the following acts:

(a) To recruit, transport, transfer; harbor, provide, or receive a person by any means, including those done under the pretext of domestic or overseas employment or training or apprenticeship, for the purpose of prostitution, pornography, sexual exploitation, forced labor, slavery, involuntary servitude or debt bondage;

(e) To maintain or hire a person to engage in prostitution or pornography;

SEC. 5. Acts that Promote Trafficking in Persons. — The following acts which promote or facilitate trafficking in persons, shall be unlawful:

(a) To knowingly lease or sublease, use or allow to be used any house, building or establishment for the purpose of promoting trafficking in persons;

Building on this principle, the Court emphasized that while Roxas’s actions facilitated the prostitution of AAA, BBB, and CCC, they did not constitute direct participation in their trafficking. His culpability stemmed from knowingly providing the venue for such activities, an act that promotes rather than directly engages in trafficking. This distinction significantly impacts the applicable penalties, as Section 10 of RA 9208 prescribes different punishments for acts of trafficking and acts that promote trafficking.

The Court also addressed the issue of whether the offense under Section 5 could be qualified by Section 6 of RA 9208, which pertains to qualified trafficking. It clarified that Section 6 applies only to violations of Section 4, not Section 5. This means that the fact that AAA and BBB were minors at the time of the offense could not elevate Roxas’s crime to qualified trafficking. This interpretation was further reinforced by the amendatory law, RA 10364, which explicitly states that only violations of Section 4 can be considered qualified trafficking.

This approach contrasts with the lower courts’ interpretation, which had imposed a harsher penalty based on the misconception that Roxas’s actions could be qualified due to the involvement of minors. The Supreme Court, however, corrected this error, aligning the punishment more closely with the specific nature of Roxas’s offense.

Having clarified the nature of Roxas’s offense, the Supreme Court turned to the issue of damages. It noted that while Roxas did not directly participate in the prostitution of AAA, BBB, and CCC, his actions contributed to their exploitation. Therefore, the Court deemed it appropriate to award moral and exemplary damages to the victims. Citing the Civil Code provisions on moral and exemplary damages, the Court explained that these awards serve to compensate the victims for the suffering they endured and to deter similar conduct in the future. As stated in Article 2217 of the Civil Code:

ART. 2217. Moral damages include physical suffering, mental anguish, fright, serious anxiety, besmirched reputation, wounded feelings, moral shock, social humiliation, and similar injury. Though incapable of pecuniary computation, moral damages may be recovered if they are the proximate result of the defendant’s wrongful act or omission.

In light of these considerations, the Supreme Court modified the Court of Appeals’ decision. It affirmed Roxas’s conviction but reclassified the offense to Acts that Promote Trafficking in Persons under Section 5(a) of RA 9208. Consequently, it reduced his sentence to imprisonment of fifteen (15) years and a fine of Five Hundred Thousand Pesos (P500,000.00). Additionally, it ordered Roxas to pay each of the victims, AAA, BBB, and CCC, moral damages of P100,000.00 and exemplary damages of P50,000.00. This decision underscores the judiciary’s commitment to ensuring that penalties are proportionate to the offense and that victims of exploitation receive adequate compensation for their suffering.

FAQs

What was the key issue in this case?	The key issue was whether Alfredo Roxas’s actions constituted trafficking in persons or merely acts that promote trafficking by leasing his room for prostitution.
What is the difference between Section 4 and Section 5 of RA 9208?	Section 4 of RA 9208 pertains to direct acts of trafficking, such as recruiting or harboring individuals for exploitation. Section 5 addresses acts that facilitate or promote trafficking, like knowingly leasing property for prostitution.
Why was Roxas’s conviction changed from qualified trafficking to promoting trafficking?	The Supreme Court ruled that Roxas’s actions of leasing his room for prostitution did not directly involve trafficking; rather, they promoted it. This distinction altered his conviction.
Can acts that promote trafficking be considered ‘qualified trafficking’?	No, the Supreme Court clarified that only violations of Section 4 on Trafficking in Persons can be qualified, according to RA 9208 and its amendments.
What was the sentence imposed on Roxas after the Supreme Court’s review?	Roxas’s sentence was modified to imprisonment of fifteen (15) years and a fine of Five Hundred Thousand Pesos (P500,000.00), reflecting the offense of promoting trafficking.
Did the victims receive any damages in this case?	Yes, the Supreme Court ordered Roxas to pay each victim (AAA, BBB, and CCC) moral damages of P100,000.00 and exemplary damages of P50,000.00.
What happened to Susan Sayo in this case?	Susan Sayo, the recruiter, passed away during the appeal process, which extinguished her criminal and civil liability.
What is the significance of RA 10364 in relation to this case?	RA 10364, the Expanded Anti-Trafficking in Persons Act of 2012, amended RA 9208, clarifying that only violations of Section 4 on Trafficking in Persons can be qualified. This amendment supported the Supreme Court’s decision to correct Roxas’s conviction.

This case serves as a crucial reminder of the importance of precise legal definitions and proportionate penalties in combating trafficking in persons. By distinguishing between direct acts of trafficking and acts that promote trafficking, the Supreme Court has ensured that the legal system appropriately addresses the various levels of involvement in these heinous crimes.

For inquiries regarding the application of this ruling to specific circumstances, please contact ASG Law through contact or via email at frontdesk@asglawpartners.com.

Disclaimer: This analysis is provided for informational purposes only and does not constitute legal advice. For specific legal guidance tailored to your situation, please consult with a qualified attorney.
Source: People v. Sayo and Roxas, G.R. No. 227704, April 10, 2019