People
vs. Lalli, et al
G.R.
No 195419
October
12, 2011
Facts:
The
respondents were found guilty in the consolidated case for Illegal Recruitment
(Criminal Case no. 21930) and Trafficking in Persons.
Ruling:
The
Court ruled against respondents with respect to Criminal Case no. 21930 for
Illegal recruitment, reasoning that the inconsistency of the testimonies of
respondents was more substantive than that of Lolita’s which involved only
minor discrepancies. The victim’s inconsistency was
held to be indicative of her candidness which meant that her statements were
not rehearsed. Conspiracy under Article 8 was also appreciated by the court in
determining the liabilities incurred by respondents. In addition, the Court
stated that the mere referral of one respondents of the victim to the other
respondent is classified as an act of recruitment under Art 13(b) of the Labor
Code.
In Criminal Case No 21908, charging
respondents for the violation of RA 9208 or The Anti-trafficking in persons
Act, the court likewise ruled against them. The Court gave no credence to the
claims of respondents and their witnesses against victim. Furthermore, provided
that their statements were true, such statements were immaterial in this case
since the crime of Trafficking in Persons can exist
even with the victim’s consent or knowledge under Section 3(a) of RA 9208.
Respondents were found guilty of
the crime of Qualified Trafficking in Persons committed by a syndicate under RA
9208 because the crime of recruitment for prostitution also constitutes
trafficking.
The prohibition of double
jeopardy was inapplicable in the case since there were several offenses to
which they were punished and had not been done so repeatedly for the same
offense.
