Santiago v. People


Santiago v. People

G.R. No. 213760

July 1, 2019


                On September 26 and 27, 2011, TV5 segment producer Espenida and his crew went to Plaza Morga and Plaza Moriones in Tondo, Manila to investigate the alleged prostitution operations in the area. They had earlier designated a confidential asset, alias "Romeo David"(David), on whom a lapel microphone was clipped, to pose as a customer and transact with the alleged pimps for a night with a minor.During the transaction, the pimps allegedly asked for P500.00.Espenida, who was on board a TV5 vehicle located about a hundred meters away from where David and the pimps were, heard the transaction through the microphone.On September 29, 2011, Espenida and his crew filed a Complaint before the Regional Police Intelligence Operations Unit, Regional Intelligence Division, Camp Bagong Diwa, reporting about the rampant human trafficking in Plaza Morga and Plaza Moriones. Acting on the Complaint, Police Senior, PO1 Ballesteros, and other police operatives conducted an entrapment operation in those areas. Later, at around 11:00 p.m., the team and David arrived at Plaza Morga. After surveying the area, David pointed to the pimps, who, upon seeing the police, ran away but were eventually caught and arrested. During trial, they were positively identified by the police officers in court as the same people apprehended that night.

After the arrest, the team proceeded to the hotel where the trafficked person, AAA, had been waiting. The officers took her into custody and brought her to the Regional Intelligence Division at Camp Bagong Diwa. According to AAA, at around 1:30 a.m. on September 30, 2011, she was about to buy coffee at Plaza Moriones when Santiago called her, offering to pay her to spend a night with a customer. He allegedly promised to pay AAA ₱350.00 out of the ₱500.00 that the customer would pay for the transaction. Later, she and Santiago went to the hotel, which was 15 meters away from Plaza Moriones.20 There, the police came and took them both into custody. AAA later confirmed during trial that Santiago was the pimp, but said that she only saw Castillo and Legazpi for the first time upon getting into the van bound for the police station. Santiago solely testified in his defense. He alleged that at around midnight of September 29, 2011, while he was selling coffee at Plaza Morga, around 25 meters away from Plaza Moriones, he was approached by David, who said that he was looking for a woman. Santiago said that he ignored the man. Then, Santiago allegedly saw AAA approach David, though he did not hear what the two had talked about. AAA later waved at Santiago and invited him to accompany her. AAA brought Santiago to a hotel, but as they were nearing it, the police arrived and arrested him.


                Whether or not CA erred in affirming the RTC


                No. In People v. Rodriguez, this Court held that the trafficked victim's testimony that she had been sexually exploited was "material to the cause of the prosecution."Here, AAA's testimony was corroborated by the testimonies of the police officers who conducted the entrapment operation. They recalled in detail the steps they had taken to verify the surveillance report and ensure that petitioner was the same person with whom the confidential informant transacted.

Contrary to petitioner's contention, the testimony of the confidential informant is not indispensable in the crime of trafficking in persons. Neither is his identity relevant. "It is sufficient that the accused has lured, enticed, or engaged its victims or transported them for the established purpose of exploitation,"which was sufficiently shown by the trafficked person's testimony alone. As explained by the Court of Appeals:


Jurisprudence consistently holds that there are compelling considerations why confidential informants are usually not presented by the prosecution. One is the need to hide their identity and preserve their invaluable service to the police. Another is the necessity to protect them from being objects or targets of revenge by the criminals they implicate once they become known. The testimony of the confidential asset is not relevant for conviction nor is it indispensable for a successful prosecution of this case because his testimony would merely be corroborative and cumulative. The testimonies of the trafficked person, AAA, clearly narrating what transpired on the trafficking incident and the police officers regarding the entrapment operation were sufficient to prove appellant's guilt of the crime charged.


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