G.R. No. 229190 , November 06, 2023
MANUEL G. SUNIGA, JR. AND ANASTACIA D. SUNIGA, PETITIONERS, VS. ROLANDO MOLINA, MA. RITCHIALYN LEODONES, LEONARDO DE GUZMAN, AND FROILAN ALEJANDRIA, RESPONDENTS.

FACTS

Petitioners Manuel Suniga, Jr. and Anastacia Suniga were charged with Large Scale Illegal Recruitment under Republic Act No. 8042 (Migrant Workers Act). The Information alleged that in June 2001, they conspired to recruit and promise overseas employment in Saipan and Korea to four private respondents, collecting a total of PHP 390,000.00 without the requisite license from the Philippine Overseas Employment Administration. The complainants filed their affidavits in December 2001. A Joint Resolution finding probable cause for estafa and illegal recruitment was issued by the prosecutor in March 2005. However, the corresponding Information was filed only in December 2013.
Upon the filing of the Information, the Regional Trial Court (RTC) issued a warrant of arrest. Petitioners filed a Motion to Quash, arguing that the offense had prescribed, claiming the five-year prescriptive period for illegal recruitment had lapsed from the 2001 acts. They also contended they were denied due process due to the prolonged preliminary investigation and that the RTC lacked jurisdiction, asserting the matter involved a money claim under the exclusive jurisdiction of the National Labor Relations Commission.

ISSUE

The core issues were: (1) whether the crime of Large Scale Illegal Recruitment had prescribed; (2) whether petitioners were denied due process; and (3) whether the RTC had jurisdiction over the case.

RULING

The Supreme Court denied the petition and affirmed the rulings of the lower courts. On the pivotal issue of prescription, the Court held that the applicable prescriptive period is twenty (20) years. Large Scale Illegal Recruitment, classified as economic sabotage under Section 7 of R.A. 8042, carries a penalty of life imprisonment and a fine. Applying Article 90 of the Revised Penal Code, crimes punishable by life imprisonment prescribe in twenty years. The reckoning point for prescription is the institution of judicial proceedings, which occurred upon the filing of the Information in 2013. Since the alleged acts transpired in 2001, the filing was well within the twenty-year prescriptive period.
The Court rejected the claim of denial of due process. Petitioners were afforded the opportunity to file counter-affidavits during the preliminary investigation but failed to do so. Any perceived delay in the investigation did not violate their constitutional rights, as they did not demonstrate that the delay was attended by vexatious, capricious, or oppressive conduct, or that it prejudiced their defense. Finally, the Court upheld the RTC’s jurisdiction. The case involves a criminal prosecution for a special law violation, not a simple labor dispute or money claim. The civil liability arising from the crime is merely incidental to the criminal action. Therefore, jurisdiction properly lies with the RTC.