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The undersigned prosecutor hereby accuses AAA of with having violated Sec. 6 (a), (d) of R.A.
No. 9208 also known as Anti-Trafficking in Persons Act of 2003 and Sec. 4 (a), (b), (e), and (k) of RA No.
11930 also known as Anti-Online Sexual Abuse or Exploitation of Children (OSAEC) and Anti-Child
Sexual Abuse or Exploitation Materials (CSAEM) Act, which he committed in the City of Bacolod, within
the jurisdiction of this court, as jurisdiction of this court, the accused did then and there engage his
nephew, BBB, and his classmates for photography sessions, which ultimately lead to the engagement of
child pornography and to the selling of said pornography to anonymous buyers over the internet.
CONTRARY TO LAW.