Regional Trial Court - Branch 4, Manila

01/09/2026

The (SC) has ruled that an affidavit of desistance, or a sworn statement withdrawing a complaint, is considered “highly suspect” when made by a victim of exploitation and cannot be used as a basis to dismiss a trafficking case.

In a Decision written by Associate Justice Samuel H. Gaerlan, the SC’s Third Division affirmed the conviction of a woman for qualified trafficking in persons involving a minor. The SC sentenced her to life imprisonment, imposed a fine of PHP 2,000,000, and ordered her to pay PHP 600,000 in damages.

The woman, who was the minor’s neighbor, recruited the minor to provide sexual services to a man in exchange for money. The minor received PHP 15,000 from the man for the sexual act, but the woman later took the money. The woman also bought the minor a cellphone and gave her PHP 3,000.

The minor’s mother discovered the incident and filed a complaint against the woman. The minor testified in court but later signed an affidavit of desistance to withdraw the charges.

During cross-examination, the minor admitted that she accepted PHP 30,000 to sign the affidavit prepared by the woman’s counsel. When the trial court questioned her further, the minor maintained that her earlier testimony was true.

Sustaining the woman’s conviction of qualified trafficking in persons under Republic Act No. (RA) 9208, or the 𝗔𝗻𝘁𝗶-𝗧𝗿𝗮𝗳𝗳𝗶𝗰𝗸𝗶𝗻𝗴 𝗶𝗻 𝗣𝗲𝗿𝘀𝗼𝗻𝘀 𝗔𝗰𝘁 𝗼𝗳 𝟮𝟬𝟬𝟯, as amended, SC held that human trafficking cases should not be dismissed based on the affidavits of desistance executed by the victims or their parents or legal guardians.

The SC explained that affidavits of desistance by victims of exploitation should be treated with caution, as they may have been made under coercion, pressure, or undue influence. This is especially true when the victims are children, who may not fully understand the consequences of withdrawing their testimony.

The SC further stressed that once a criminal case has been filed in court, the complainant can no longer decide whether the case should proceed.

The State has an interest in prosecuting the crime and is the party affected by the dismissal of the criminal action. Thus, an affidavit of desistance, especially one executed while trial is ongoing, does not, by itself, justify dismissal of the case.

Read the full text of the press release at https://sc.judiciary.gov.ph/?p=172431

Read the full text of the Decision at
https://sc.judiciary.gov.ph/?p=167240

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

14/08/2026

02/06/2026

This June, the Philippines marks Judiciary Month, celebrating the 125th anniversary of the Supreme Court.

Declared under Presidential Proclamation No. 1265, s. 2026, the observance calls on government agencies, local government units, the private sector, and civil society to support and partake in the commemoration.

Established on June 11, 1901 through Act No. 136 of the Philippine Commission, the Supreme Court has stood as a pillar of justice—first led by Chief Justice Cayetano Arellano.

In line with this milestone year, the Court unveils a series of activities under the theme: “SC: 125 Years of Tradition and Innovation.”

Stay tuned for updates through the official social media channels of the Supreme Court.

05/01/2026

The has laid down guideposts for proving who owns or controls a social media account in criminal cases.

In a Decision written by Associate Justice Ramon Paul L. Hernando, the SC’s First Division affirmed the conviction of an individual (###) for committing psychological violence under Section 5 (i) of the 𝘈𝘯𝘵𝘪-𝘝𝘪𝘰𝘭𝘦𝘯𝘤𝘦 𝘈𝘨𝘢𝘪𝘯𝘴𝘵 𝘞𝘰𝘮𝘦𝘯 𝘢𝘯𝘥 𝘛𝘩𝘦𝘪𝘳 𝘊𝘩𝘪𝘭𝘥𝘳𝘦𝘯 (𝘈𝘯𝘵𝘪-𝘝𝘈𝘞𝘊) 𝘈𝘤𝘵 against his ex-girlfriend (AAA) by posting derogatory statements about her on 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬.

The SC sentenced ### to up to eight years in prison, imposed a PHP 100,000 fine, and ordered ### to undergo psychological counseling or psychiatric treatment.

The SC stressed that in criminal cases, the prosecution must prove not only the elements of the crime but also the identity of the offender.

It explained that for crimes committed through social media, the basic features of the platform such as 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬, must be considered.

Noting that 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬 is widely used in the Philippines, the SC held that a 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬 account can easily be created by anyone claiming to be at least 13 years old with an email address or mobile number.

Once an account is created, the user can add friends, exchange private messages, and post statements, photos, or videos visible to others depending on the user’s privacy settings. Fake or dummy accounts can easily spread, enabling disinformation, identity theft, or crimes.

Given this, the SC ruled that guideposts are necessary to establish who owns or controls a social media account. It said the following must be shown to prove ownership or access:

1. Admission of ownership or authorship;
2. Being seen accessing the account or composing the post;
3. Containing information known only to the offender or a few people;
4. Language consistent with the offender’s characteristics;
5. Records from the internet service provider, telecommunications company, or social media site, and results from device forensic analysis showing geolocation features, and other attributes linking the account to the offender;
6. Acts consistent with previous posts; or
7. Other instances showing ownership, access, or authorship.

Applying these, the SC found that several factors proved ### wrote the 𝘍𝘢𝘤𝘦𝘣𝘰𝘰𝘬 post. The account name bore his full name, and the profile photo showed him with his child from his current live-in partner.

AAA’s sister had also received messages from the same account for years.

Read the full text of the Press Release at https://sc.judiciary.gov.ph/?p=158535.

Read the full text of the Decision at https://sc.judiciary.gov.ph/?p=158446.

Copying of this content is subject to the SC PIO’s Credit Attribution Policy: https://sc.judiciary.gov.ph/credit-attribution-policy/.

05/01/2026