Victims of trafficking face profound suffering that may last their lifetime, the incalculable injustice perpetrated by people who make a living out of deceiving unsuspecting victims , taking advantage of their vulnerability. They must be penalized.
Thus declared the Supreme Court, through Senior Associate Justice Marvic Leonen, in the case of People vs. Valencia (G.R. No. 234013, June 16, 2021) that involved minor girls being offered to foreigners for the sexual services.
Human trafficking is a significant violation of fundamental human rights, also dubbed as “modern-day slavery “
The main law against human trafficking in the Philippines is R.A. 9208 (Anti-Trafficking in Persons Act of 2003), which makes it a crime to traffic in persons for purposes like sexual exploitation, forced labor, or organ removal. Other relevant laws include RA 7610 (protection of children), RA 6955 (anti-mail order bride), and RA 8042 (migrant workers).
The elements of trafficking in persons under RA. No. 9208 based on the act, means and purpose are:
(1) The ACT of “recruitment, transportation, transfer or harbouring, or receipt of persons with or without the victim’s consent or knowledge, within or across national borders.”
(2) The MEANS used which include “threat or use of force, or other forms of coercion, abduction, fraud, deception, abuse of power or of position, taking advantage of the vulnerability of the person, or, the giving or receiving of payments or benefits to achieve the consent of a person having control over another; and
(3) The PURPOSE of trafficking is exploitation which includes “exploitation or the prostitution of others or other forms of sexual exploitation, forced labor or services, slavery, servitude or the removal or sale of organs.”
In People vs Casio (G.R. No. 211465. December 3, 2014), Leonen said that trafficking in persons is a deplorable crime. It is committed even though the person knew about or consented to the act of trafficking.
“Human trafficking indicts the society that tolerates the kind of poverty and its accompanying desperation that compels the victims to endure indignities. It reflects the weaknesses of that society even as it convicts those who deviantly thrive in such hopelessness.”
“We should continue to strive for the best of our world, where our choices of human intimacies are real choices, and not the last resort taken just to survive. Human intimacies enhance our best and closest relationships. It serves as a foundation for two human beings to face life’s joys and challenges while continually growing together with many shared experiences. The quality of our human relationships defines the world that we create also for others.”
“We express the hope that our people and our government unite against everything inhuman. We contribute to a commitment to finally stamp out slavery and human trafficking.
Leonen added “ There are more victims out there. They, too, deserve to be rescued. They, too, need to be shown that in spite of what their lives have been, there is still much good in our world.”
A 2024 paper by the US Department of State noted that traffickers exploit women and children from rural communities, conflict- and disaster-affected areas, and impoverished urban centers in sex trafficking, forced domestic work, forced begging, and other forms of forced labor in tourist destinations and urban areas around the country.
It added that traffickers exploit men in forced labor in the agricultural, construction, fishing, and maritime industries, sometimes through debt-based coercion.
It added that “some corrupt officials allegedly accept bribes to facilitate migration outside of regular channels for overseas workers, operate sex trafficking establishments, facilitate production of fraudulent identity documents, or overlook irregular labor recruiters.”
Former Bamban, Tarlac mayor Alice Guo was recently found guilty of qualified human trafficking and sentenced to reclusion perpetua by Pasig City Regional Trial Court Branch 167 in a case tied to the illegal operations of a Philippine offshore gaming operation (POGO) hub in her town.
It stemmed from last year’s police raid on the Zun Yuan Technology compound, which operated on a property leased through Guo’s company.
The Expanded Anti-Trafficking in Persons Act penalizes individuals who own or manage establishments used to facilitate trafficking and related crimes.
The decision came out on the same day that the 11th Manila International Dialogue on Human Trafficking (MID) was being held in Makati City last November 20, 2025.
Bringing together government agencies, civil society, international partners, and the private sector, the MID has fostered meaningful dialogue and collective action to address emerging trafficking trends, strengthen policies, and promote victim-centered solutions.
(Atty. Dennis R. Gorecho heads the Seafarers’ Division of the Sapalo Velez Bundang Bulilan Law Offices. For comments, e-mail info@sapalovelez.com, or call 09175025808)