GR 108028; (July, 1996) (Digest)
G.R. No. 108028 July 30, 1996
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CRISTINA M. HERNANDEZ, accused-appellant.
FACTS
Accused-appellant Cristina Hernandez was charged with Illegal Recruitment in Large Scale. The prosecution presented four witnesses who testified that in December 1988, Hernandez, representing herself as the general manager of Philippine Thai Association, Inc., recruited them for factory jobs in Taipei. She required and received placement fees totaling P22,500 from each applicant, issuing receipts signed by her alleged treasurer, Liza Mendoza, in her presence. Hernandez promised deployment before year-end, which never materialized, and she refused to return the money upon demand.
The defense consisted solely of Hernandez’s testimony. She denied ever meeting the complainants, recruiting anyone, or receiving money. She admitted being the nominal president of Philippine-Thai but claimed it was only engaged in the barong tagalog business and that she did not participate in its operations. She asserted her office was for a logging corporation.
ISSUE
The core issue is whether the prosecution proved beyond reasonable doubt all elements of Illegal Recruitment in Large Scale, particularly that Hernandez, a non-licensee, undertook recruitment activities.
RULING
The Supreme Court affirmed the conviction. The prosecution successfully established all elements of the crime. The testimonies of the four complainants were positive, categorical, and consistent in detailing how Hernandez, through representations of her capacity to deploy workers abroad, recruited them and collected fees. Their collective testimony constituted ample proof of recruitment of three or more persons, making the crime large scale.
The Court found Hernandez’s defense of bare denial inherently weak and unpersuasive against the clear and convincing positive identification by the witnesses. Her admission of being president of Philippine-Thai, coupled with the stipulation during trial that neither she nor the company was licensed by the POEA to recruit workers, conclusively proved the element of lack of license or authority. The trial court’s assessment of witness credibility is accorded great respect, as it was in a better position to observe their demeanor. The defense failed to show any ill motive for the complainants to falsely testify. Thus, the guilt of the appellant for the crime of Illegal Recruitment in Large Scale was proven beyond reasonable doubt.