Santiago v. People
G.R. No. 213760
July 1, 2019
FACTS:
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.
ISSUE:
Whether
or not CA erred in affirming the RTC
HELD:
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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