Case Spotlight: People of the Philippines vs. XXX
Ponente: Associate Justice Paul Hernando | Date Decided: January 22, 2025
This week, we take a closer look at a significant ruling from the Supreme Court involving the protection of minors under our anti-trafficking laws.
The case involves two 14-year-old girls who were recruited by the accused to work as massage therapists in a spa, an establishment allegedly known for offering “extra services” to clients. According to the defense, the minors voluntarily sought employment, and the accused neither coerced them nor trained them to provide such extra services. Instead, she claimed to have simply provided standard massage training.
The Regional Trial Court found the accused guilty of Attempted Trafficking in Persons, noting that although the minors managed to escape before being fully exploited, the circumstances already pointed to a clear intent to traffic.
On appeal, the Court of Appeals modified the conviction to Qualified Trafficking in Persons, recognizing the involvement of minors and the gravity of the offense. The penalty was increased to life imprisonment, along with monetary damages amounting to millions of pesos.
Still insisting on her innocence, the accused elevated the case to the Supreme Court, arguing that she had no malicious intent and that her actions were merely meant to help the minors find work.
But the High Court was unequivocal.
In rejecting the appeal, the Court emphasized that the consent of a minor is never a valid defense under Republic Act No. 9208, as amended by RA No. 10364. It stated:
“A minor victim’s knowledge or consent is rendered meaningless due to the coercive, abusive, or deceptive means typically used by perpetrators of human trafficking. Even absent these means, a minor’s consent is not considered freely given.”
The Supreme Court affirmed that the accused was guilty of Qualified Trafficking in Persons, reiterating key legal principles:
- When the victim is a child, trafficking is qualified, which carries harsher penalties.
- Actual exploitation does not need to occur, recruiting minors for the purpose of sexual exploitation is already a consummated crime.
- Trafficking can be committed even without force or deception if it takes advantage of a child’s vulnerability.
Quoting the Court:
“Recruitment, transportation, transfer, harboring, adoption or receipt of a child for the purpose of exploitation shall be considered trafficking in persons even without any of the means stated under the law.”
“Republic Act No. 9208 does not require the victims to be actually subjected to prostitution or sexual exploitation for the crime to be complete. The act of recruitment with intent to exploit is enough.”
This decision reinforces the strong protective stance of the law when it comes to minors and serves as a reminder that the crime of trafficking begins not at the moment of abuse, but at the moment of intent and recruitment.
📚 Read the full decision here:
🔗 People of the Philippines vs. XXX (G.R. No. 273990)
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