REPUBLIC OF THE PHILIPPINES

REGIONAL TRIAL COURT

9th Judicial Region
Branch __
Zamboanga City
THE PEOPLE OF THE PHILIPPINES
-verus-

CHIZ WISE aka CHIZ,

a certain MOTHER LILIA
X------------------------------------------X

Criminal Case No: _____

for VIOLATION OF
ANTI-HUMAN TRAFFICKING
UNDER SEC. 4 (a) and (f), IN
RELATION TO SEC. 6 and 10
RA 9208, AS AMENDED BY
RA 10364

I N F O R M AT I O N
The undersigned Assistant City Prosecutor of Zamboanga City hereby
accuses CHIZ WISE and a certain MOTHER LILIA, of the crime of
QUALIFIED HUMAN TRAFFICKING, defined and penalized under Section 4
(a) and (f), in relation to Section 6 and 10 of Republic Act No. 9208, as amended
by Republic Act 10364, committed as follows:
That on or about the 17th of January 2015 in La Purisima, Zamboanga City,
the above named accused, in conspiracy with one another, did then and there
willfully, unlawfully and knowingly RECRUIT HEART ESCUDERO, and
thereafter did then and there willfully, unlawfully and knowingly,
TRANSPORT and TRANSFER her from Barangay Bibincahan, Sorsogon
City to Zamboanga City to work at Reach Out Entertainment belonging to or
managed by accused CHIZ WISE located in La Purisima, Zamboanga City,
which is within the jurisdiction of this Honorable Court. And in pursuit of
the aforesaid conspiracy, said accused CHIZ WISE and MOTHER LILIA,
did then and there willfully, unlawfully and knowingly RECEIVE,
HARBOR and EMPLOY said HEART ESCUDERO as a prostitute in said
establishment, to her damage and prejudice.
That the crime was attended by the qualified circumstance of minority,
complainant HEART ESCUDERO, being 17 years of age at the time of
recruitment and employment.
CONTRARY TO LAW.
City of Zamboanga City, Philippines, 16th February, 2015.

PETER MEDALLE
Assistant City Prosecutor
MCLE Compliance No. III-00012
June 06,2013
APPROVED:
RICARDO G. CABARON
City Prosecutor
MCLE Compliance No. III-00011
June 06, 2014
C E R T I F I C AT I O N
I HEREBY CERTIFY, under oath, that I have examined the
complainant and the witnesses in this case; that on the basis of the sworn
statements and other evidence submitted before me, there is a reasonable ground to
believe that a crime has been committed and that the accused is probably guilty
thereof; that the accused afforded the opportunity to submit controverting
evidence.
PETER MEDALLE
Assistant City Prosecutor
MCLE Compliance No. III-00012
June 06,2014
SUBSCRIBED AND SWORN to before me this 9 th of February 2015 in the
City of Zamboanga, Philippines.
PETER MEDALLE
Assistant City Prosecutor
MCLE Compliance No. III-00012
June 06,2015
Witnesses:
1.
2.
3.
4.

Special Agent Peter Malinis National Bureau of Investigation, Zamboanga City

Madonna Spears Pasonanca, Zamboanga City
Angelino Nojolly Pasonanca, Zamboanga City
And others.

BOND RECOMMENDED: ______________