People v. Mupas

People v. Rodriguez, G.R. No.
211721, September 20, 2017

FACTS:
Rodriguez was charged with trafficking committed in a large scale for trafficking 3 persons
(qualified trafficking, Sec. 4(a), Sec. 6(c), RA 9208).
The evidence of the prosecution heavily anchored on (PO1 Escober), on the joint sworn affidavit of
the arresting officers, and on a photocopy of the pre-marked P500 bill.
He testified: PO1 Escober was at the police station preparing for Oplan Bugaw to eliminate
prostitution on Quezon Avenue. While parked at the target area, PO1 Escober was flagged down
by Rodriguez who allegedly offered the sexual services of 3 pickup girls. PO1 Escober readily gave
Rodriguez the pre-marked ₱500 bill as payment. His backup entered the scene and aided in the
arrest. PO1 Escober retrieved the pre-marked bill. The officers brought Rodriguez and the (3)
pickup girls to the police station.
Rodriguez said that he was only selling cigarettes on Quezon Avenue when he was arrested by the
police officers.
RTC ruled Rodriguez guilty beyond RD. It gave more weight to the positive testimony of POl
Escober over Rodriguez's unsubstantiated denial.
On appeal, Rodriguez anchored his defense on the failure of the prosecution to present any
evidence that would establish that he recruited, transported, or transferred the alleged (3) women
for the purpose of prostitution. These women were not presented in court and neither did they
execute any sworn statement. CA affirmed RTC.
ISSUE: W/N Rodriguez’ guilt was proven beyond reasonable doubt. - NO.
HELD: Acquitted.
It is a basic rule that the conviction of the accused must rest not on the weakness of the defense
but on the strength of the prosecution based on the constitutional presumption that the accused is
innocent unless his guilt is proven beyond reasonable doubt.
Proof beyond reasonable doubt does not mean such degree of proof as, excluding the possibility of
error, to produce absolute certainty. Only moral certainty is required, or that degree of proof which
produces conviction in an unprejudiced mind.
Elements of the trafficking in persons:
Recruitment of persons with or without the victim’s consent
Means used: threat, force, fraud, taking advantage of vulnerability
Purpose of trafficking is exploitation: prostitution, forced labor
The prosecution failed to prove the presence of these elements beyond reasonable doubt. The
second and third were not even proven.
Only PO1 Escober testified as to the actual unfolding of circumstances which led him to believe
that Rodriguez was committing human trafficking. It lacks the material details to convince us that
Rodriguez had committed human trafficking.
On cross-examination, PO1 Escober testified that the accused [said], "Sir, sir, babae, sir," and
interpreted it as he was offering to him [a] woman. Then he asked him the cost.
The circumstances about the initial contact between PO1 Escober and Rodriguez and their
negotiations came out only during crossexamination. PO1 Escober's direct testimony showed the
fact that he had in his possession the pre-marked ₱500.00 bill and that he was able to retrieve it
from Rodriguez after the arrest. There was no mention about how Rodriguez allegedly called on
the three (3) pickup girls and offered them for sexual purposes.
The exchanges between PO1 Escober and Rodriguez would suggest that PO1 Escober already
knew what Rodriguez meant when he said "Sir, sir, babae, sir," and thus assumed that Rodriguez
was offering women for sex. However, his testimony is bare as to the fact that the offer of women
was explicitly for sexual purposes. It also lacked the necessary details on how Rodriguez allegedly
called on the pickup girls to display them for PO1 Escober to choose from.
When there is reasonable doubt, the evidence must be interpreted in favor of the accused. Under
the equipoise rule, if the evidence admits two interpretations, one of which is consistent with guilt,
and the other with innocence, the accused must be given the benefit of the doubt and should be
acquitted.
Apart from the deficient testimony of PO1 Escober, the prosecution did not bother to present the
testimonies of the alleged victims. These women would be in the best position to say that
Rodriguez had recruited them by giving them payments or benefits in exchange for sexual
exploitation.
Again, PO1 Escober' s lone testimony lacked the material details to establish all the elements of
the crime. Where there is reasonable doubt as to the guilt of the accused, he must be acquitted
even though his innocence may be doubted since the constitutional right to be presumed innocent
until proven guilty can only be overthrown by proof beyond reasonable doubt. To conclude,
because of this doubt that lingers in our mind, Rodriguez must be acquitted.

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People v. Rodriguez, G.R. No.

211721, September 20, 2017

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