REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH ____
PEOPLE OF THE PHILIPPINES
PERSONS
-versusand

FOR: QUALIFIED TRAFFICKING IN

[Sec. 6 (a) and (c) in rel. to Secs. 4(a), 3
10 (c) of RA 9208 and to Sec. 5(a) of

RA 8369]

(Family Courts)

ANTONIO CRUZ y SANTOS

(Brgy. Prinza, Teresa, Rizal)
JOSE LIM y CINCO
(Brgy. Prinza, Teresa, Rizal)
CARLOS TIROL y PARDO
(No. 4, Bonifacio St., Tondo, Manila)
Accused.
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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.