GR 112180; (August, 1997) (Digest)
G.R. No. 112180 August 15, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. MILDRED VILLAS y NIQUE, accused-appellant.
FACTS
Accused-appellant Mildred Villas was charged with Illegal Recruitment in Large Scale. The Information alleged that from November 1990 to April 1991, in Davao City, she recruited and promised employment in Canada to four individuals—Alfonsa Acierda, Teresita Villegas, Nenita Balisalisa, and Ligaya Rentura—without securing the required license from the Department of Labor and Employment. The prosecution established that Villas represented herself as having the capacity to recruit workers for Canada, collected processing fees ranging from P2,000 to P11,800 from the complainants, and issued case numbers from the Canadian Immigration Assistance Service (CIAS). A certification from the Philippine Overseas Employment Administration confirmed she had no license to recruit.
ISSUE
Whether the trial court erred in convicting accused-appellant Mildred Villas of the crime of Illegal Recruitment in Large Scale.
RULING
The Supreme Court affirmed the conviction. The legal logic rests on the concurrence of three elements for illegal recruitment in large scale: (1) the accused undertook recruitment activities, (2) she did not have the required license or authority from the DOLE, and (3) she committed the same against three or more persons individually or as a group. All elements were proven beyond reasonable doubt. The appellant’s defense of bare denial cannot prevail over the positive, categorical, and consistent testimonies of the four complainants, which were corroborated by an NBI agent and a POEA certification. The act of promising employment abroad and collecting fees constitutes recruitment and placement under the Labor Code. The number of victims qualifies the act as large scale, constituting economic sabotage punishable by life imprisonment. The Court emphasized that factual findings of the trial court on witness credibility are accorded high respect and are binding on appeal, especially when, as here, the appellant failed to demonstrate any overlooked fact that would cast doubt on her guilt. The penalty of life imprisonment and fine was upheld, with orders for restitution to the complainants.