G.R. No. 121777 January 24, 2001
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CAROL M. DELA PIEDRA, accused-appellant.

FACTS

Accused-appellant Carol M. dela Piedra was charged with illegal recruitment in large scale. The information alleged that on or about January 30, 1994, in Zamboanga City, she, without a license from the POEA, willfully and feloniously offered and promised employment in Singapore for a fee to three individuals: Maria Lourdes Modesto, Nancy Araneta, and Jennelyn Baez. Modesto had advanced P2,000.00 for the promised employment, which did not materialize. Following a surveillance operation and an entrapment conducted by the POEA and CIS agents on February 2, 1994, dela Piedra was arrested. During the operation, an agent posing as an applicant was given a bio-data form, and dela Piedra was found in possession of several filled-out application forms. A POEA certification confirmed she had no license to recruit.
The Regional Trial Court convicted dela Piedra of illegal recruitment in large scale. On appeal, she questioned her conviction and assailed the constitutionality of the law defining the crime, arguing it was vague for failing to clearly distinguish between “license” and “authority,” thereby violating due process. She also claimed the prosecution failed to prove her guilt beyond reasonable doubt, particularly contesting the testimonies of the private complainants.

ISSUE

The primary issues were: (1) the constitutionality of the law penalizing illegal recruitment, and (2) the sufficiency of evidence to prove illegal recruitment in large scale.

RULING

The Supreme Court affirmed the conviction and upheld the constitutionality of the law. On the constitutional challenge, the Court ruled that the terms “license” and “authority” as used in the Labor Code are not vague. A “license” refers to a document issued by the Department of Labor authorizing a person or entity to operate a private employment agency, while “authority” is a document issued to authorize an individual or entity to recruit for a specific principal. The law provides a sufficiently definite standard, and a person of ordinary intelligence can comprehend what is prohibited—recruitment without the necessary government grant. The law is not void for vagueness.
On the merits, the Court found the evidence sufficient to establish illegal recruitment in large scale. The testimonies of the three private complainants, corroborated by the POEA certification and the entrapment operation, convincingly proved that dela Piedra undertook recruitment activities by promising overseas employment for a fee without the required license or authority. The crime of illegal recruitment in large scale is constituted by recruitment of three or more persons, individually or as a group. All elements were present. However, the Court modified the penalty, reducing it from life imprisonment to an indeterminate penalty ranging from six years and one day of prision mayor as a minimum to twelve years and one day of reclusion temporal as a maximum, and a fine of P100,000.00, in line with prevailing jurisprudence.