People vs. Nangcas (2018)

PEOPLE OF THE PHILIPPINES vs. GLORIA NANGCAS

G.R. No. 218806, June 13, 2018

MARTIRES, J.:

Facts: An Information was filed charging appellant for Violation of the "Anti-Trafficking in Persons Act of 2003", which alleges that the accused, unlawfully recruit, transport four (4) women, three of them are minors, by taking advantage of the vulnerability of said victims for the purpose of offering and selling said victims for forced labor, that is, by promising them local employment (as househelpers in Camella Homes, Cagayan de Oro City) with a monthly salary of PhP1,500.00 each and that they could go home every Sunday, but instead, said accused brought them to Marawi City and sold them for PhP1,600.00 each to their great damage and prejudice.

Nangcas denied the allegations claiming that she had no idea that the employer would no longer be needing house helpers; hence, with no money to pay for the fare, she had no other choice but to stay with Baby Abas in Marawi City.

Issue: Whether or not appellant’s guilt was established beyond reasonable doubt.

Ruling: Yes, appellant’s guilt was established beyond reasonable doubt.

Section 4 of RA 9208 provides: It shall be unlawful for any person, natural or juridical, to commit any of the following acts: (a) To recruit, transport, transfer; harbor, provide, or receive a person by any means, including those done under the pretext of domestic or overseas employment or training or apprenticeship, for the purpose of prostitution, pornography, sexual exploitation, forced labor, slavery, involuntary servitude or debt bondage;

Section 6. Qualified Trafficking in Persons. - The following are considered as qualified trafficking: (a) When the trafficked person is a child;

In this case, Nangcas induced and coaxed the victims to go with her by promising the victims and their parents that their daughters would be working within Cagayan De Oro City, with an enticing salary of P1,500.00 per month. In Marawi, the victims were constrained to work with the intention to save money for their fare going back home; however, when they asked for their salary they were told that it had already been given to Nangcas.

Ratio Decidendi: Deceit is the false representation of a matter of fact intended to deceive another so that he shall act upon it to his legal injury.

Gist: This an appeal from the Decision of the CA, which affirmed the Decision of the RTC, finding appellant guilty beyond reasonable doubt of the crime of Qualified Trafficking in Persons under Section 4 in relation to Section 6 of Republic Act No. 9208.