GR 133563; (March, 1999) (Digest)
G.R. No. 133563 March 4, 1999
BRIDGET BONENG Y BAGAWILI, petitioner, vs. PEOPLE OF THE PHILIPPINES, respondent.
FACTS
Petitioner Bridget Boneng y Bagawili was charged with Illegal Recruitment under Article 38(a) of the Labor Code. The Information alleged that on September 24, 1993, in Baguio City, she promised employment abroad for a fee to complainant Ma. Teresa Garcia without possessing the required license or authority from the Philippine Overseas Employment Administration. After the prosecution presented its evidence, the petitioner filed a demurrer to evidence, waiving her right to present defense evidence. The Regional Trial Court found her guilty beyond reasonable doubt and sentenced her to imprisonment.
The petitioner appealed to the Court of Appeals, contending that the complainant’s testimony was perjured and uncorroborated, and that the documentary evidence seized from her office was obtained through an unconstitutional search and seizure. She argued that the prosecution failed to prove she was engaged in recruitment, as no other applicants were presented. The Court of Appeals affirmed the trial court’s decision in its entirety, prompting the petitioner to elevate the case to the Supreme Court via a Petition for Review on Certiorari.
ISSUE
Did the Court of Appeals err in affirming the petitioner’s conviction for illegal recruitment?
RULING
No, the Court of Appeals did not err. The Supreme Court denied the petition, affirming the conviction. The Court emphasized that it is not a trier of facts and that factual findings of the Court of Appeals, especially when affirming the trial court and supported by substantial evidence, are binding and conclusive. The petitioner’s waiver of her right to present evidence foreclosed her opportunity to object to the prosecution’s evidence on appeal.
On the merits, the Court upheld the finding that all elements of illegal recruitment were proven: the petitioner undertook recruitment activities, and she lacked the necessary license or authority, as certified by the POEA. The Court also ruled that the warrantless arrest and seizure of evidence were lawful under Section 5(b), Rule 113 of the Rules of Court, as the offense had just been committed in the presence of the complainant, and the peace officers had personal knowledge of facts indicating the petitioner committed it when they apprehended her and recovered the marked money and recruitment documents. Therefore, the petitioner’s guilt was established beyond reasonable doubt.