GR 112175; (July, 1996) (Digest)
G.R. No. 112175 July 26, 1996
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ENGINEER RODOLFO DIAZ, accused-appellant.
FACTS
Accused-appellant Rodolfo Diaz was charged with Illegal Recruitment in Large Scale. The prosecution established that in July 1992, three complainants—Mary Anne Navarro, Maria Theresa Fabricante, and Maria Elena Ramirez—were introduced to Diaz, who was then detained at the CIS Detention Center in Davao City. Through intermediaries, they learned Diaz was recruiting workers for Brunei. During a meeting at the detention center, Diaz confirmed he was recruiting, outlined the requirements, and specified fees, including a P2,500 processing fee and a P65,000 placement fee. All three complainants subsequently paid processing fees to Diaz at his residence. They were promised employment as salesgirls in Brunei with a monthly salary of $700 for four hours of daily work. Diaz represented that his agency’s owner was Erlinda Romualdez and assured them it was a government project. The complainants later discovered Diaz had no license from the Department of Labor and Employment.
ISSUE
Whether the accused-appellant is guilty beyond reasonable doubt of the crime of Illegal Recruitment in Large Scale.
RULING
Yes. The Supreme Court affirmed the conviction. The legal logic rests on the elements of Illegal Recruitment in Large Scale under Article 38(b) of the Labor Code, as amended. First, the accused undertook recruitment activities by promising overseas employment to the three complainants. Second, he did so without the required license or authority from the POEA. Third, he committed the act against three or more persons individually or as a group. The court found the testimonies of the three complainants credible, consistent, and sufficient to establish all elements. Their detailed accounts of the promises, meetings, and payments were corroborative and remained unrebutted by convincing evidence from the defense. The court emphasized that the offense is committed once illegal recruitment activities are undertaken without a license, regardless of whether the victims were actually deployed abroad. The defense of denial and the subsequent return of the processing fees could not overcome the positive identification and the established illegal recruitment scheme. The penalty of life imprisonment and a fine of P100,000 was thus upheld.