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 prosecution presented multiple complainants, including Dionisio Basmayor, Medardo Valerio, Reynaldo Reyes, Renato Gonzales, Rufino Pascua, and Benjamin Alejo. Their collective testimonies established a common pattern: the appellant promised them jobs in Japan, solicited and received placement fees, issued receipts for the payments, and subsequently failed to deploy them or return their money. Basmayor testified to giving large sums and assisting in the appellant’s office.
The defense of the appellant was a denial. He claimed he merely advised Basmayor on tourist travel and did not receive money from any complainant. He denied signing the receipts and knowing the other victims prior to the fiscal’s investigation. However, the prosecution evidence included receipts bearing his signature and a promissory note he executed in favor of complainants Pascua and Imperial, promising to return their P9,000. The trial court found him guilty, prompting this appeal.

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 concurrence of two essential elements under Article 38(b) of the Labor Code, as amended: (1) the accused undertook recruitment activities without the necessary license or authority from the Department of Labor, and (2) the recruitment was committed against three or more persons individually or as a group. The prosecution conclusively proved both. First, it was established that “CIB International Promotion and General Services” was not a licensed recruitment agency. Second, the testimonies of seven complainants, corroborated by receipts and a promissory note, convincingly demonstrated that the appellant personally engaged in recruitment by promising overseas jobs and collecting fees. The Court found the denial of the appellant inherently weak and unpersuasive against the positive, categorical, and consistent testimonies of the victims. His acknowledgment of the payments through the executed promissory note particularly bolstered the prosecution’s case. The defense’s attempt to implicate Basmayor as the principal was rejected, as the evidence showed the appellant was the direct recruiter and beneficiary; Basmayor acted merely as a conduit under the appellant’s instructions. The crime, involving three or more persons, constitutes Illegal Recruitment in Large Scale, which is economic sabotage punishable by life imprisonment. The findings of the trial court on witness credibility are accorded great respect. All elements of the crime were proven beyond reasonable doubt.