GR 119361; (February, 2001) (Digest)
G.R. No. 119361 . February 19, 2001.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CORAZON NAVARRA (At Large), RODOLFO NAVARRA, SR. and JOB NAVARRA, accused. RODOLFO NAVARRA, SR. and JOB NAVARRA, accused-appellants.
FACTS
Accused-appellants Rodolfo Navarra, Sr. and Job Navarra, along with Corazon Navarra (at large), operated Rodolfo Navarra’s Travel Consultant and General Services (RNTCGS), an agency recruiting workers for Taiwan. Multiple complainants, including Merlie Villesca, Gliceria Marinas, and Beinvenida Amutan, testified that they applied and paid substantial placement fees to the agency through the accused or their intermediary. They were promised overseas employment but were never deployed.
The Philippine Overseas Employment Administration (POEA) confirmed that neither RNTCGS nor the individual accused were licensed or authorized to recruit workers for overseas employment. An entrapment operation led to an arrest after a marked payment was received. An Information was filed charging the accused with Illegal Recruitment in Large Scale.
ISSUE
Whether the accused-appellants are guilty beyond reasonable doubt of the crime of Illegal Recruitment committed in large scale.
RULING
Yes, the Supreme Court affirmed the conviction. Illegal recruitment is defined under Article 13(b) of the Labor Code and is committed by any person who, without the requisite license or authority from the POEA, undertakes any recruitment activity, including promising or advertising for employment abroad for a fee. The prosecution conclusively proved that appellants engaged in recruitment activities without the necessary POEA license or authority.
The crime escalates to Illegal Recruitment in Large Scale, constituting economic sabotage, when committed against three or more persons individually or as a group. The trial court’s summary of testimonies established that at least six complainants were victimized, satisfying the element of large scale. The Court found the testimonies of the complainants credible and consistent. The defense of denial proffered by the appellants could not prevail over the positive identification and detailed accounts of the prosecution witnesses.
The acts of Rodolfo and Job, from interviewing applicants, accepting fees, and making promises of deployment, demonstrated a common criminal design. Their coordinated actions established conspiracy. The penalty for Illegal Recruitment in Large Scale is life imprisonment and a fine of P100,000.00, which the Court upheld.
