PEOPLE OF THE PHILIPPINES, PLAINTIFF-APPELLEE, VS. RYAN DE CASTRO Y SERRANO, ACCUSED-APPELLANT.
- G.R. Number: G.R. No. 274959
- Promulgated: 2025-04-23
- Ponente: LAZARO-JAVIER, J.
Doctrine
## Facts of the Case On February 13, 2018, the Anti-Human Trafficking Division of the NBI received a referral concerning rampant sexual exploitation of women. An entrapment operation was organized where NBI agents posed as customers. Around 1:00 a.m. on February 14, 2018, Ryan De Castro (De Castro) and Renato Hernandez (Hernandez) approached the poseur customers, offering four girls (AAA, BBB, CCC, and DDD) for sexual services at PHP 500.00 each at a nearby lodging house. Agent Bati handed the marked money to De Castro, after which the pre-arranged signal was given, leading to the arrest of De Castro and Hernandez. Hernandez died during the trial, leading to the dismissal of the case against him. De Castro denied the charges, claiming he was merely waiting for a friend when he was approached by seemingly inebriated men asking for girls. He alleged that Hernandez, an acquaintance, interrupted and made the offer, then asked him to call the girls. He complied and was subsequently arrested. The trial court found De Castro guilty of qualified trafficking in persons, sentencing him to life imprisonment and a fine of PHP 2,000,000.00, along with moral and exemplary damages to the victims. The Court of Appeals affirmed this decision. De Castro appealed to the Supreme Court, maintaining his innocence and challenging the credibility of prosecution witnesses and the finding of conspiracy. ## Issues 1. Did the Court of Appeals err in affirming De Castro's conviction for Qualified Trafficking in Persons? 2. Did the Court of Appeals err in finding that De Castro conspired with Hernandez to commit the crime? ## Decision / Rationale **Issue 1:** The Court **affirmed** De Castro's conviction for Qualified Trafficking in Persons. The Court found that all elements of the offense were established. De Castro approached the poseur customers, offering the sexual services of the victims for a fee. This was corroborated by the testimony of BBB, one of the victims, who stated that De Castro (whom she knew as Bakla) explicitly called her and the other victims, indicating they were being offered for sexual activities. De Castro's defense of denial and his claim that he did not know Hernandez were contradicted by his own admission in open court that he was acquainted with Hernandez from jail, and by BBB's testimony that she had met De Castro a week prior to the arrest. The Court upheld the concurrent findings of the lower courts regarding the credibility of the prosecution witnesses, noting that De Castro failed to prove any ill motive on their part. The Court further noted that De Castro took advantage of the victims' vulnerability and underprivileged status. **Issue 2:** The Court **affirmed** the finding of conspiracy between De Castro and Hernandez. The Court held that De Castro's actions, including initially approaching the poseur customers, summoning the victims, and telling them that " *may kukuha daw ng babae, apat* " (someone would be getting four girls), clearly demonstrated a singularity of intent and action to offer the victims for sexual exploitation. The Court reiterated that direct proof is not required to show conspiracy; concerted action is sufficient. Thus, even if there was a perceived inconsistency in whose hands the marked money was exactly received, it becomes immaterial as the act of one conspirator is the act of all. The crime was committed in large scale as it involved three or more persons, namely AAA, BBB, and CCC. The penalty of life imprisonment, a fine of PHP 2,000,000.00, and moral and exemplary damages to the victims were deemed correct, with a 6% interest per annum on monetary awards from finality of the decision. ## Doctrines - **Elements of Trafficking in Persons (Republic Act No. 9208, as amended by Republic Act No. 10364):** - The act of "recruitment, obtaining, hiring, providing, offering, transportation, transfer, maintaining, harboring, or receipt of persons with or without the victim's consent or knowledge, within…
Keywords
Republic Act No. 9208 Section 4(e), Republic Act No. 9208 Section 6(c), Republic Act No. 10364, Amended Administrative Circular No. 83-2015, Revised Penal Code Article 266-A, Republic Act No. 8353, Nacar v. Gallery Frames, Qualified Trafficking in Persons, Sexual Exploitation, Conspiracy, Credibility of Prosecution Witnesses, Life Imprisonment, Moral Damages, Exemplary Damages, Reasonable Doubt, Large Scale Trafficking, Appeal Dismissed, Conviction Affirmed, Guilty Beyond Reasonable Doubt, Monetary Awards with Legal Interest