GR 110391; (February, 1997) (Digest)
G.R. No. 110391 . February 7, 1997.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. DOLORES DE LEON Y MISAJON, accused-appellant.
FACTS
The accused-appellant, Dolores de Leon, was charged with Illegal Recruitment in Large Scale. The information alleged that between July and September 1992, in Manila, she recruited and promised employment in Jeddah/Saudi Arabia to numerous individuals without securing the required license from the Department of Labor and Employment. The prosecution presented several witnesses, including Charlene Tatlonghari, Rodante Sunico, Guillermo Lampa, Manuel Cabusao, Joseph Chavez, and Roberto Porio. Their collective testimonies established a common pattern: appellant represented herself as a recruiter, often claiming connection to “All Seasons Manpower,” offered specific jobs abroad, collected varying amounts of money as processing or placement fees, and consistently failed to issue official receipts. She repeatedly promised and postponed departure dates. The applicants eventually discovered her promises were false, leading to her arrest.
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 statutory definition of recruitment and placement under the Labor Code, which includes any act of canvassing, enlisting, contracting, transporting, or promising employment for a fee. The court found the testimonies of the private complainants credible, consistent, and sufficient to prove all elements of the crime. Appellant engaged in recruitment activities by promising overseas jobs to multiple individuals and collecting fees from them. The absence of a receipt does not negate the transaction, as the law criminalizes the act of recruitment without a license, not merely the issuance or non-issuance of a receipt. Crucially, the number of persons recruited (three or more) qualified the act as large-scale illegal recruitment, which is considered economic sabotage under the law and carries the penalty of life imprisonment. Her defense was deemed unsubstantiated against the overwhelming evidence presented by the prosecution. The court emphasized the gravity of the offense, which preys on the hopes of citizens seeking better opportunities, and affirmed the trial court’s imposition of life imprisonment and a fine of One Hundred Thousand Pesos (P100,000.00).