MANILA, Philippines — The Supreme Court has ruled that an affidavit of desistance from a victim of exploitation cannot serve as grounds to dismiss a human trafficking case, saying such statements can result from coercion, pressure or undue influence.
In a decision promulgated Feb. 19, 2026, and made public Tuesday, the Supreme Court’s Third Division affirmed the conviction of a woman for qualified trafficking in persons involving a minor.
The court said the woman recruited her neighbor, who was a minor, to provide sexual services to a man in exchange for money.
The man paid the victim P15,000, but the recruiter took most of the money and gave the minor P3,000 and a cellphone.
The victim’s mother discovered the exploitation and filed a complaint against the woman.
The minor testified in court but later executed an affidavit of desistance seeking to withdraw the complaint.
During cross-examination, however, the victim said she signed the affidavit, which the woman’s lawyer prepared, after receiving P30,000.
The Regional Trial Court convicted the woman under the Anti-Trafficking in Persons Act of 2003, as amended by the Expanded Anti-Trafficking in Persons Act of 2012. The Court of Appeals later upheld the conviction, which the Supreme Court affirmed.
The woman received a life imprisonment sentence, a P2-million fine and an order to pay the victim P600,000 in damages.
The Supreme Court said courts must treat affidavits of desistance from trafficking victims, their parents or legal guardians with caution and should not use them as the sole basis for dismissing a case.
The court said victims may execute such affidavits under coercion, pressure or undue influence.
“This is especially true when the victims are children, who may not fully understand the consequences of withdrawing their testimony,” the Supreme Court said.
The court also stressed that once prosecutors file a criminal case in court, the complainant no longer controls whether the case will proceed.
The ruling reinforces the principle that human trafficking prosecutions involve the state’s responsibility to pursue criminal cases even when victims later withdraw their complaints.
