Republic of the Philippines
REGIONAL TRIAL COURT
7th Judicial Region
Lapu-Lapu City
Branch 27
People of the Philippines,
Plaintiff,
Criminal Case No. 24-13254
- versus - For: Violation of RA 9208 as
amended by RA 10364
(Trafficking in Persons)
JOJO SANTOS,
Accused.
x--------------------x
INFORMATION
The undersigned Associate City Prosecutor accuses JOJO
SANTOS, 17 years old who acted with discernment, and a resident of
Barangay Bantay, Lapu-Lapu City, Cebu Philippines, for violation of
Republic Act No. 9208 (Trafficking in Persons) as amended by RA
10364, committed as follows:
That sometime in June 2023 and subsequently thereafter in
Lapu-Lapu City, Cebu, Republic of the Philippines, and within
the jurisdiction of this Honorable Court, the above-named
accused, by means of threat, coercion, fraud, deception, by taking
advantage of the vulnerability of the giving and receiving of
payments or benefits to achieve the consent of Sweet Reyes, 15
years old and born on 2008, who was in financial need and naïve
due to her age, did then and there, willfully, unlawfully and
feloniously engaged in recruiting, obtaining, providing, offering,
maintaining persons for prostitution and for sexual exploitation
as in fact Sweet Reyes was recruited, obtained, provided, offered,
maintained, and harbored by the above-named accused and she
was required to engage in sexual activities with foreigners/clients
through online means by undressing and acting lewdly and
provocatively in front of the camera in LAPU-LAPU CITY, to her
damage and prejudice.
That the said victim suffered actual and moral damages in the
amount as may be rewarded by the Honorable Court under the
provisions of the New Civil Code of the Philippines.
CONTRARY TO LAW.
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Lapu-Lapu City, Cebu, Philippines, 27 December 2024.
ORANGE L. LOPEZ
Assistant City Prosecutor
Roll No. 100450/ IBP Lifetime No. 018926
MCLE Compliance No. VII – 0007582
Valid Until April 20, 2025
Approved:
KIWI Q. RAMOS
Chief, Office of the City Prosecutor
Roll No. 79451/ IBP Lifetime No. 123456
MCLE Compliance No. VII – 00075863
Valid Until July 20, 2025
Bail Recommended: 200,000 pesos as per DOJ Department
Circular 13 of 2018
Witnesses:
• Sweet Reyes
Brgy. Bolo, Lapu-Lapu City, Cebu
• Candy Reyes (Victim’s Mother)
Brgy. Bolo, Lapu-Lapu City, Cebu
• Police Corporal Cresenciano Saladaga
(Investigating Officer) – Lapu-Lapu City, Cebu
Enclosures:
1. Preliminary Investigation Resolution
2. Complaint Letter
3. Affidavit of Complaint
4. Birth Certificate
5. Digital Forensic Report
6. Medico-legal Certificate
7. Counter-Affidavit of the Accused
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CERTIFICATION
This is to certify that as shown by the records the undersigned,
an authorized officer, that there is reasonable certainty of conviction
and a prima facie case exists based on the evidence-at-hand including
but not limited to witnesses, documentary evidence, real evidence, and
the like, and such evidence, on its own and if left uncontroverted by
accused, shall be sufficient to establish all the elements of the crime or
offense charged, and consequently warrant a conviction beyond
reasonable doubt; that the accused was informed of the complaint and
of the evidence submitted against him and was given an opportunity to
submit controverting evidence.
ORANGE L. LOPEZ
Assistant City Prosecutor
Roll No. 100450/ IBP Lifetime No. 018926
MCLE Compliance No. VII – 0007582
Valid Until April 20, 2025
SUBSCRIBED AND SWORN to before me this 27th day of
December 2024 at Lapu-Lapu City, Cebu, Philippines.
BERRY F. REYES
Assistant City Prosecutor
Roll No. 99940/ IBP Lifetime No. 017894
MCLE Compliance No. VII – 0006879
Valid Until April 14, 2025
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