G.R. No. 150530 ; February 20, 2003
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALEX BAYTIC, accused-appellant.

FACTS

Accused-appellant Alex Baytic was convicted by the Regional Trial Court of Quezon City for Illegal Recruitment in Large Scale and sentenced to life imprisonment with a fine. The prosecution evidence established that in September 1998, Baytic, accompanied by Kennedy Hapones, went to the residence of Ofelia Bongbonga. He represented to those present, including complainants Ofelia Bongbonga, Millie Passi, and Nolie Bongbonga, that he could deploy workers to Italy as utility personnel, requiring payment for document processing. Relying on these representations, the three complainants gave him amounts totaling ₱11,500, for which Baytic issued receipts. He failed to appear for a scheduled interview, prompting the complainants to search for him, later discovering his arrest for similar activities.
In his defense, Baytic denied the accusations, claiming he was himself a victim of Kennedy Hapones, whom he identified as the actual illegal recruiter. He asserted that Hapones had recruited him and other applicants, and that the complainants merely vented their anger on him after Hapones absconded. The trial court, however, found the testimonies of the three complainants to be straightforward, consistent, and corroborated by documentary evidence, giving them full credence over Baytic’s denial.

ISSUE

Whether the prosecution proved beyond reasonable doubt all elements of the crime of Illegal Recruitment in Large Scale against accused-appellant Alex Baytic.

RULING

Yes, the Supreme Court affirmed the conviction. The crime of Illegal Recruitment in Large Scale requires: (1) the accused undertakes recruitment activities as defined under Article 13(b) or any prohibited practice under Article 34 of the Labor Code; (2) the accused has no valid license or authority to engage in such recruitment; and (3) the accused commits the act against three or more persons. All elements were proven. Baytic’s act of promising overseas employment in Italy to the complainants and collecting fees constitutes recruitment under the law. The Philippine Overseas Employment Administration certified he had no license, satisfying the second element. The third element was met by the victimization of three identifiable persons.
The Court rejected Baytic’s defense of denial and his claim that Hapones was the real recruiter. His unsubstantiated denial cannot prevail over the positive, categorical, and corroborated testimonies of the three complainants, who had no ill motive to falsely accuse him. The receipts he issued were concrete evidence of the transactions. The trial court’s assessment of witness credibility is accorded great respect. Thus, his actions constituted economic sabotage punishable by life imprisonment and a fine under Republic Act No. 8042 .