G.R. No. 126933 . February 23, 2001.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ILUMINADA DELMO VALLE y SOLETA, accused-appellant.

FACTS

Accused-appellant Iluminada Delmo Valle y Soleta was charged with Illegal Recruitment in Large Scale under two separate Informations. The charges alleged that between August 1995 and March 1996, in Makati City, she recruited and promised employment in London, England, to numerous individuals, collecting fees ranging from P4,000 to P6,000 as processing fees and demanding a P120,000 placement fee payable through salary deductions. She represented herself as having the capacity to send workers abroad for jobs as salesladies, waitresses, and service crew. After repeated postponements of their departure, the complainants became suspicious and verified with the Philippine Overseas Employment Administration (POEA), which certified that accused-appellant was neither licensed nor authorized to recruit workers. The complainants then reported the matter to the National Bureau of Investigation, leading to her entrapment and arrest.
At trial, the prosecution presented multiple complainants who positively identified accused-appellant as the person who recruited them and collected fees. The defense, however, denied the charges, claiming she was merely an employee of Claire Recruitment and General Services (CRGS), a licensed agency. She asserted that her activities were on behalf of CRGS and that she did not personally recruit the complainants for a fee.

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 crime of Illegal Recruitment in Large Scale has three essential elements: (1) the accused undertook recruitment activities defined under Article 13(b) or made prohibited acts under Article 34 of the Labor Code; (2) the accused did not have the required license or authority from the POEA; and (3) the accused committed the acts against three or more persons individually or as a group. All elements were proven beyond reasonable doubt. Accused-appellant’s promise of employment abroad for a fee constitutes recruitment under the law. The POEA certifications confirmed her lack of license. The testimonies of numerous complainants, who consistently identified her and detailed her promises and fee collections, established that she recruited more than three persons. Her defense of being an employee of a licensed agency was rejected for being self-serving and uncorroborated; she failed to present the agency owner as a witness or explain why recruitment was conducted at her residence instead of the agency’s official address. Thus, her actions constituted economic sabotage, punishable by life imprisonment and a fine under Article 39 of the Labor Code.