G.R. No. 107084 May 15, 1998
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DELIA SADIOSA y CABENTA, accused-appellant.

FACTS

Accused-appellant Delia Sadiosa was charged with illegal recruitment. The information alleged that from January to March 1992, in Pasay City, knowing she was not a licensed recruiter, she falsely represented she could secure employment as domestic helpers abroad for Benilda Sabado, Marcela Tabernero, Erly Tuliao, and Cely Navarro, collected P8,000.00 from each, and failed to deploy them. Upon arraignment, she pleaded not guilty. The prosecution presented the four complainants, who testified that they were introduced to Sadiosa by Arsenia Conse. Sadiosa assured them of jobs in Kuwait, demanded processing fees, issued receipts, and promised departure dates that never materialized. Virginia Santiago of the POEA testified Sadiosa was neither licensed nor authorized to recruit. The defense claimed Sadiosa merely received the money on behalf of Mrs. Ganura of Staff Organizers, Inc., presenting a remittance of P25,000.00 and claiming a special power of attorney, though she was not listed with the POEA. The trial court found her guilty of illegal recruitment in large scale, sentencing her to life imprisonment, a P100,000.00 fine, and ordering restitution to the complainants.

ISSUE

The primary issue is whether the information filed against the accused-appellant was valid and sufficient, particularly regarding the designation of the offense and the clarity of the accusations, and whether the trial court’s judgment complied with the constitutional requirement to state clearly and distinctly the facts and the law on which it was based.

RULING

The Supreme Court affirmed the trial court’s decision. The information, though captioned simply as “illegal recruitment,” sufficiently alleged the elements of illegal recruitment in large scale under Article 38(b) of the Labor Code: (1) the accused engaged in recruitment and placement; (2) without the required license or authority; and (3) committed against three or more persons. The allegations informed the accused of the nature and cause of the accusation, satisfying constitutional and procedural requirements. The Court held that the information’s references to false representations did not render it defective or multiplicitous; they merely described how the illegal recruitment was consummated. The defense raised by the accused-appellant showed she understood the charges. The Court found no need to resolve other assigned errors, as the conviction for illegal recruitment in large scale, an offense involving economic sabotage punishable by life imprisonment and a fine under Article 39(a) of the Labor Code, was proper.