REPUBLIC OF THE PHILIPPINES NATIONAL CAPITAL JUDICIAL REGION REGIONAL TRIAL COURT BRANCH ____

PEOPLE OF THE PHILIPPINES -versus-

FOR: QUALIFIED TRAFFICKING IN PERSONS [Sec. 6 (a) and (c) in rel. to Secs. 4(a), 3 and 10 (c) of RA 9208 and to Sec. 5(a) of RA 8369] (Family Courts)

MARINA B. ANGELES (Project 58, Quezon City) (No. 4, Bonifacio St., Tondo, Manila) Accused. x-----------------------------------------------------------------------------------------x INFORMATION The Undersigned Assistant City Prosecutor accuses ANTONIO CRUZ y SANTOS, JOSE LIM y CINCO and CARLOS TIROL y PARDO of the crime of Qualified Trafficking in Persons penalized under Section 6 (a) and (c) in relation to Sections 4 (a), 3 and 10 (a) and (c) of RA 9208 and in further relation to Section 5 (a) of RA 8369 (Family Courts), committed as follows: That on or about the 3rd of June 2004 in the Municipality of Binangonan, Province of Rizal, the above named accused ANTONIO CRUZ y SANTOS, JOSE LIM y CINCO and CARLOS TIROL y PARDO, in conspiracy with one another, and by means of force, threats and coercion, and for the purpose of exploitation, such as prostitution and other forms of sexual exploitation, but under the pretext of domestic employment, did then and there willfully, unlawfully and knowingly RECRUIT ROSA SANTOS, and thereafter did then and there willfully, unlawfully and knowingly, TRANSPORT and TRANSFER her to a house belonging to or managed by accused CARLOS TIROL y PARDO located in Tondo, Manila, which is within the jurisdiction of this Honorable Court. And in pursuit of the aforesaid conspiracy, said accused CARLOS TIROL y PARDO, did then and there willfully, unlawfully and knowingly RECEIVE, HARBOR and EMPLOY said ROSA SANTOS as a prostitute in said house, to her damage and prejudice. That the crime was attended by the qualified circumstances of minority, complainant ROSA SANTOS, being 16 years of age, and that the crime was committed by a syndicate of three (3) persons.

CONTRARY TO LAW.