Arambullo v. People


Arambullo v. People

G.R. No. 241834

July 24, 2019


The RTC and CA convicted Fernando B. Arambulo for the crime of Qualified Trafficking in Persons. petitioner and his minor son, Dominique Dimple Arambulo9 (Dominique), invited the latter's three (3) schoolmates who were also minors, namely AAA, BBB, and CCC, 10 to their house sometime in 2011. It was then revealed that the purpose of the meeting was to discuss petitioner's plans to commit robberies with the help of AAA, BBB, and CCC. Upon learning about this, CCC expressed his desire to leave but petitioner got angry and punched him; thus, he was forced to join the group. AAA, BBB, and CCC then similarly testified that not only was petitioner the mastermind of the series of robberies they subsequently committed against various people, but he was also the driver of their getaway tricycle.


                Whether or not the CA correctly upheld petitioner's conviction for Qualified Trafficking in Persons.


                Yes. Section 3 (a) of RA 9208 defines the term "Trafficking in Persons" as the "recruitment, transportation, transfer or harboring, or receipt of persons with or without the victim's consent or knowledge, within or across national borders by means of 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 persons, or, the giving or receiving of payments or benefits to achieve the consent of a person having control over another person for the purpose of exploitation which includes at a minimum, the 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 same provision further provides that "the recruitment, transportation, transfer, harboring or receipt of a child for the purpose of exploitation shall also be considered as 'trafficking in persons' even if it does not involve any of the means set forth in the preceding paragraph."The crime becomes qualified when any of the circumstances found under Section 6 of the law is present.




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