The Supreme Court partly granted the appeal, acquitting XXX234512 of child prostitution under Section 5(a) of Republic Act No. 7610 due to the prosecution’s failure to prove the victims’ minority. However, the Court affirmed the conviction for trafficking under Section 4(a) of Republic Act No. 9208, as amended. This decision highlights the critical importance of proving all elements of a crime beyond reasonable doubt, especially concerning the age of victims in child exploitation cases, while underscoring that even without proof of minority, trafficking charges can still stand when the exploitation of individuals is evident.

When Silence Speaks: How the Law Weighs Omitted Details and Unproven Ages in Exploitation Cases

This case revolves around XXX234512, who was accused of child prostitution and trafficking involving her own daughters, AAA234512 and BBB234512. The prosecution alleged that XXX234512 procured her daughters for an American man named Peter, who subjected them to sexual abuse. However, the defense argued that the prosecution failed to prove all elements of the crimes, particularly the minority of the victims and inconsistencies in their testimonies. The central legal question is whether the prosecution successfully established beyond reasonable doubt that XXX234512 committed the crimes of child prostitution and trafficking, considering the lack of evidence regarding the victims’ ages and the alleged inconsistencies in their testimonies.

The Supreme Court, in reviewing the case, emphasized that an appeal in criminal cases opens the entire case for review, including aspects not raised by the parties. The initial charges against XXX234512 included violations of Section 5 of Republic Act No. 7610, specifically Section 5(a), which addresses acts of engaging in, promoting, facilitating, or inducing child prostitution. To establish guilt under this section, the prosecution must prove that the accused acted as a procurer of a child prostitute and that the child was below 18 years of age. Crucially, under Section 5(a)(3) of Republic Act No. 7610, the act of taking advantage of influence or relationship with a child to procure them as a child prostitute is punishable, especially if the child is subjected to sexual intercourse or lascivious conduct under Section 5(b) of the same Act.

However, the Court found a significant deficiency in the prosecution’s case regarding the victims’ ages. The Regional Trial Court (RTC) noted that the victims’ birth certificates were not presented during trial, and the Court of Appeals (CA) failed to adequately address how the victims’ minority was established. The Supreme Court underscored the importance of proving the victims’ minority, citing People v. Pruna, which provides clear guidelines for establishing age as an element of a crime. According to People v. Pruna:

1. The best evidence to prove the age of the offended party is an original or certified true copy of the certificate of live birth of such party.
2. In the absence of a certificate of live birth, similar authentic documents such as baptismal certificate and school records which show the date of birth of the victim would suffice to prove age.
3. If the certificate of live birth or authentic document is shown to have been lost or destroyed or otherwise unavailable, the testimony, if clear and credible, of the victim’s mother or a member of the family either by affinity or consanguinity who is qualified to testify on matters respecting pedigree such as the exact age or date of birth of the offended party pursuant to Section 40, Rule 130 of the Rules on Evidence shall be sufficient.
4. In the absence of a certificate of live birth, authentic document, or the testimony of the victim’s mother or relatives concerning the victim’s age, the complainant’s testimony will suffice provided that it is expressly and clearly admitted by the accused.
5. It is the prosecution that has the burden of proving the age of the offended party. The failure of the accused to object to the testimonial evidence regarding age shall not be taken against him.
6. The trial court should always make a categorical finding as to the age of the victim.

In this case, none of these circumstances were met. The victims’ birth certificates were not presented, nor were there any similar authentic documents or sufficient testimonies from family members to establish their ages. Given that minority is an essential element of child prostitution, the prosecution’s failure to prove this element led to XXX234512’s acquittal on these charges. As the element of minority was not duly established, accused-appellant cannot be made liable for child prostitution under Section 5(a) of Republic Act No. 7610, thus We acquit her.

Despite the acquittal on child prostitution charges, the Supreme Court affirmed XXX234512’s conviction for trafficking in persons. Trafficking in persons, as defined in Section 3(a) of Republic Act No. 9208, involves the recruitment, transportation, transfer, harboring, or receipt of persons with or without the victim’s consent, for the purpose of exploitation. The elements of trafficking in persons, as derived from People v. Casio, include:

1. The act of “recruitment, transportation, transfer or harboring, or receipt of persons with or without the victim’s consent or knowledge, within or across national borders.”
2. The means used which include “threat or use of force, or other forms of coercion, abduction, fraud, deception, abuse of power or of position, taking Advantage of the vulnerability of the person, or, the giving or receiving of payments or benefits to achieve the consent of a person having control over another.”
3. The purpose of trafficking is exploitation which includes exploitation or the prostitution of others or other forms of sexual exploitation, forced labor or services, slavery, servitude or the removal or sale of organs.”

The Court found that these elements were present in XXX234512’s actions. The evidence showed that she procured her daughters for Peter, who subjected them to sexual exploitation. AAA234512 testified that XXX234512 brought her to meet with Peter in a hotel, where he sexually abused her. BBB234512 corroborated this, testifying that she was also brought to a room by XXX234512 to meet with Peter, where she was left alone with him and subjected to unwanted physical contact. Both children testified that they saw XXX234512 receive money after their encounters with Peter, indicating that she was profiting from their exploitation.

The Court rejected the defense’s argument that the victims’ testimonies were inconsistent, finding that any discrepancies did not negate the fact of the crime’s commission. The fact that AAA234512 and BBB234512 had different recollections of who was present in the hotel room does not invalidate the central fact that they were exploited by Peter and that XXX234512 facilitated this exploitation. The Court also upheld the credibility of the victims’ testimonies, noting that trial courts have a unique opportunity to assess the sincerity and spontaneity of witnesses, especially children who have suffered sexual abuse. Further, this Court refrains from disturbing such finding unless it is shown that the trial court missed some fact or circumstance that could affect the result of the case. In this respect, emphasis is placed on the decree of respect given by courts on children’s testimony of the sexual abuse they suffered.

The Supreme Court also addressed the CA’s finding that XXX234512 was guilty of qualified trafficking based on her admission of their parent-child relationship during the pre-trial conference. The Court clarified that this admission alone is insufficient to prove the circumstance of relationship, citing People v. Mendoza, Jr., which held that such a relationship must be sufficiently established by competent and independent evidence, given the seriousness of the penalty involved. However, even without the element of qualified trafficking, the Court found sufficient evidence to convict XXX234512 of trafficking under Section 4(a) of Republic Act No. 9208, as amended by Republic Act No. 10364, which carries a penalty of imprisonment for 20 years and a fine of not less than PHP 1,000,000.00 but not more than PHP 2,000,000.00.

The Court also upheld the award of damages to the victims, following People v. XXX, which provided for PHP 500,000.00 each as moral damages and PHP 100,000.00 each as exemplary damages. These amounts will accrue interest at a rate of 6% per annum from the finality of the decision until fully paid.

FAQs

What was the key issue in this case?	The key issue was whether the prosecution successfully proved beyond reasonable doubt that XXX234512 committed the crimes of child prostitution and trafficking, considering the lack of evidence regarding the victims’ ages and the alleged inconsistencies in their testimonies.
Why was XXX234512 acquitted on the child prostitution charges?	XXX234512 was acquitted on the child prostitution charges because the prosecution failed to provide sufficient evidence, such as birth certificates or credible testimonies, to prove that the victims were minors at the time of the incidents.
What evidence supported the trafficking conviction?	The trafficking conviction was supported by testimonies from the victims, AAA234512 and BBB234512, who described how XXX234512 procured them for an American man named Peter, who subjected them to sexual exploitation, and how XXX234512 received money after these encounters.
What are the elements of trafficking in persons under Philippine law?	The elements of trafficking in persons include the act of recruitment, transportation, transfer, or harboring of persons, the means used (such as threat, force, coercion, or deception), and the purpose of exploitation, including sexual exploitation.
What is the significance of People v. Pruna in this case?	People v. Pruna is significant because it establishes the guidelines for proving the age of an offended party in cases involving minors, outlining the types of evidence that are admissible and the burden of proof on the prosecution.
Why did the Court reject the argument that the victims’ testimonies were inconsistent?	The Court found that any inconsistencies in the victims’ testimonies were minor and did not negate the central facts of the case, particularly that they were exploited by Peter and that XXX234512 facilitated this exploitation.
What damages were awarded to the victims in this case?	The victims were awarded PHP 500,000.00 each as moral damages and PHP 100,000.00 each as exemplary damages, with these amounts accruing interest at a rate of 6% per annum from the finality of the decision until fully paid.
What was the final ruling of the Supreme Court?	The Supreme Court partly granted the appeal, acquitting XXX234512 of child prostitution but affirming the conviction for trafficking, sentencing her to 20 years of imprisonment and a fine of PHP 2,000,000.00, along with the aforementioned damages.

This case underscores the importance of meticulous evidence collection and presentation in cases involving vulnerable individuals. While the acquittal on child prostitution charges highlights the necessity of proving all elements of a crime, the affirmed conviction for trafficking demonstrates that even without establishing the victims’ minority, those who facilitate their exploitation can still be held accountable under the law.

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 OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. XXX234512, G.R. No. 234512, March 05, 2025