G.R. No. 87542 March 6, 1990
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CRISOSTOMO BUGAOAN y IGNACIO alias TOM, accused-appellant.

FACTS

The accused-appellant, Crisostomo Bugaoan, was charged with Illegal Recruitment in Large Scale. The information alleged that from February to March 1987, in Cavite City, he represented himself as the manager of “CIB International,” an unlicensed firm, and induced seven individuals to deliver various sums of money for promised overseas employment in Japan. Upon arraignment, he pleaded not guilty. The complaint was later amended to include two more complainants. The prosecution presented multiple complainants who testified consistently. They stated that Bugaoan promised them jobs in Japan, collected fees for document processing, issued receipts, and then disappeared without fulfilling his promises. For instance, Dionisio Basmayor gave P15,000 initially and a total of P78,000. Others like Medardo Valerio, Reynaldo Reyes, and Renato Gonzales gave amounts from P3,000 to P3,500. Rufino Pascua and Reynaldo Imperial gave P4,500 each, and after their scheduled departure failed, Bugaoan executed a promissory note for P9,000, which he did not honor. Benjamin Alejo, a tricycle driver, also gave P6,000 for promised work in Saudi Arabia.
The defense consisted of Bugaoan’s denial. He claimed he merely advised Basmayor on tourist travel to Japan and did not receive money from any complainant. He denied signing the receipts and knowing the other complainants before meeting them at the fiscal’s office and in court. However, he admitted signing a promissory note presented by Pascua but claimed it was for a different purpose. The trial court found him guilty, sentencing him to life imprisonment and ordering restitution. He appealed, arguing the prosecution failed to prove his guilt beyond reasonable doubt and that the testimonies were inconsistent.

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 legal logic rests on the elements of illegal recruitment in large scale under Article 38(b) of the Labor Code, as amended: (1) the accused engages in recruitment and placement activities, (2) without a valid license or authority from the POEA, and (3) the offense is committed against three or more persons individually or as a group. The Court found all elements conclusively established. First, Bugaoan’s acts of promising overseas jobs, collecting fees, and processing documents constitute recruitment and placement. Second, it was undisputed that “CIB International” had no license. Third, the offense involved nine complainants, satisfying the “large scale” element.
The Court dismissed the defense of denial, emphasizing that the positive, categorical, and consistent testimonies of the complainants prevailed. Their detailed accounts of giving money to Bugaoan, often in his presence and with receipts he issued, were credible. The promissory note he executed for Pascua and Imperial was particularly damning, as it directly acknowledged a debt related to processing their travel papers. The Court also clarified that while complainant Basmayor sometimes acted as a conduit, this did not exonerate Bugaoan, who was the principal recruiter instructing the transactions. The alleged inconsistencies in the testimonies were minor and did not affect the core narrative of illegal recruitment. Therefore, his guilt was proven beyond reasonable doubt.