G.R. No. 148198 ; October 1, 2003
PEOPLE OF THE PHILIPPINES, appellee, vs. ELIZABETH “BETH” CORPUZ, appellant.

FACTS

The appellant, Elizabeth Corpuz, was charged with Illegal Recruitment in Large Scale under R.A. No. 8042 . The information alleged that in July 1998, she recruited four individuals for overseas employment in Taiwan without the required POEA license, collected processing fees, and subsequently failed to deploy them or reimburse their expenses. The complainants initially applied at Alga-Moher International Placement Agency, dealing with its President, Mrs. Evelyn Reyes. On the day they paid their fees, Mrs. Reyes was absent but called the appellant, her secretary, to receive the money on her behalf. The appellant complied. When deployment failed, the complainants sought a refund. Mrs. Reyes claimed the money appellant remitted was for a personal debt.
The prosecution established that the agency’s license was suspended by the POEA a day before the appellant received the payments. The complainants later executed affidavits of desistance after receiving refunds from the appellant’s relative. At trial, the appellant denied any illegal recruitment activity, asserting she merely acted as an employee following her employer’s direct order to collect the fees, which she promptly turned over, and had no knowledge of the license suspension.

ISSUE

Whether the prosecution proved beyond reasonable doubt that the appellant committed illegal recruitment by representing herself as having the capacity to recruit workers abroad.

RULING

The Supreme Court reversed the conviction and acquitted the appellant. The legal logic centered on the essential elements of illegal recruitment under R.A. 8042, particularly the need for proof that the accused engaged in recruitment and placement activities without a license, and that she represented herself as having the capacity to do so. The Court found the evidence insufficient to prove these elements beyond moral certainty.
The appellant’s act of merely receiving the money upon the specific instruction of her employer, the licensed agency’s president, did not constitute the “canvassing, enlisting, or contracting” contemplated by law. There was no evidence she solicited the applicants, promised them employment, or represented herself as having the authority to recruit independently. Her role was purely ministerial as a secretary. The failure to deploy stemmed from the agency’s suspended license, a circumstance outside her control. The refund issue was also mitigated by the subsequent repayment. The evidence admitted an interpretation consistent with innocence—that the principal offender may have been the agency’s president. Applying the principle that where evidence admits two interpretations, one consistent with innocence, the accused must be acquitted, the Court held that the prosecution failed to overcome the presumption of innocence.