SC: Child sexual abuse victims' past sexual behavior not valid in any criminal proceeding
The Supreme Court (SC) said a child sexual abuse victim's past sexual behavior is not valid in any criminal proceeding.
In a website entry on Oct. 25, the SC said its second division found Adrian "Alicia Bakla" Adrales guilty of violating Republic Act No. 9208 or the Anti-Trafficking of Persons Act of 2003.
Adrales approached a 14-year-old girl and arranged for her to have sex with a certain Emong for P800. This arrangement happened two more times with different men.
The Regional Trial Court convicted Adrales and the Court of Appeals affirmed the conviction, prompting the present appeal before the SC.
The high court found the elements of RA 9208 were "clearly met," saying trafficking occurs when individuals are recruited, transported, or transferred—regardless of consent or knowledge—under threats, coercion, deception, or abuse of power for exploitative purposes such as prostitution.
It's considered qualified trafficking when it involves minors, carrying a life sentence.
The SC found that Adrales befriended the girl and recruited her for prostitution. He took advantage of her vulnerability, the court said, by offering her money in exchange for engaging in sexual activities with different men.
It also dismissed Adrales's defense that she was already a prostitute before they met.
Under the "sexual abuse shield rule" in Section 30(a) of the Rule on Examination of a Child Witness, evidence showing that victims engaged in other sexual behavior isn't admissible in any criminal proceeding involving child sexual abuse.
The sexual abuse shield rule aims to protect victims against the invasion of privacy, potential embarrassment, and sexual stereotyping that happen when intimate sexual details are disclosed in public. This protection also encourages victims to speak up against their abusers.
Adrales was sentenced to life imprisonment and fined P6 million. He was also ordered to pay the girl P1.8 million in damages.