Cited Laws
TL;DR — Ruling
The appeal is unmeritorious.
Accordingly, the RTC sentenced her to suffer the penalty of life imprisonment and to pay a fine of PHP 2,000,000.00. However, the RTC found reasonable doubt that the trafficking in persons was committed by a syndicate considering the insufficiency of evidence to implicate the alleged owner and other employees of xxxxxxxxx Bar. Thus, the RTC acquitted Macatangay and her co-accused in Criminal Case Nos. 12-43926, 12-43927, 12-43928, 12-43929, 12-43930, 12-43931, 12-43932, 12-43933, 12-43935, 12-43936, and 12-43937 . Further, the RTC also acquitted Macatangay of violating Section 6(c) of the same law. [14] In convicting Macatangay in Criminal Case No. 12-43934 , the RTC explained that she was positively identified by AAA267832 as the one who ordered the latter to perform sexual services for customers in exchange for money. Coupled with the fact that AAA267832 was only 16 years old at the time she was employed as a GRO, all the elements for qualified trafficking in persons under Section 4(a), in relation to Section 6(a), of RA 9208 were established. [15] Aggrieved, Macatangay appealed her conviction in Criminal Case No. 12-43934 to the CA. The CA Ruling In a Decision [16] dated June 10, 2022, the CA upheld Macatangay's conviction with modification, further imposing on her civil liability ex delicto in the amounts of PHP 500,000.00 as moral damages, and PHP 100,000.00 as exemplary damages, both of which with interest of 6% per annum from finality of the ruling until full payment. [17] In so ruling, the CA likewise found that in Criminal Case No. 12-43934 , the elements of qualified trafficking in persons under Section 4(a), in relation to Section 6(a), of RA 9208 were established. In this regard, the CA pointed out that AAA267832's testimony proves that she, as a minor, was recruited and harbored at xxxxxxxxx Bar as a GRO who performs sexual services in exchange for money, and that it was Macatangay as floor manager who referred AAA267832 to customers expecting sexual services. The CA also held that because of AAA267832's minority, too, the element of coercion, threat, force, or fraud need not be proven. Finally, following case law, the CA saw fit to hold award moral and exemplary damages. [18] Consequently, Macatangay filed a Notice of Appeal [19] on July 7, 2022. On December 27, 2023, Macatangay, through the Public Attorney's Office, filed a manifestation [20] stating that she will no longer file a supplemental brief considering that all the issues raised had already been threshed out and refuted in her appellant's brief. The People, through the Solicitor General, manifested similarly [21] on December 6, 2023. The Issue Before the Court The sole issue in this case is whether Macatangay's guilt for the crime of qualified trafficking under Section 6(a) of RA 9208 was proven beyond reasonable doubt. The Court's Ruling The appeal is unmeritorious. The Court, in reviewing criminal cases, is guided by the principle that the trial court's factual findings
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