REPUBLIC OF THE PHILIPPINES

NATIONAL CAPITAL JUDICIAL REGION

REGIONAL TRIAL COURT
BRANCH ____

PEOPLE OF THE PHILIPPINES FOR: QUALIFIED TRAFFICKING IN PERSONS

-versus- [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)

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.
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.