G.R. No. 97028 May 21, 1993
THE PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ALICIA B. GAOAT, accused-appellant.

FACTS

On September 22, 1987, Alicia B. Gaoat, along with Magdalena Abenir Irons and Domingo B. Babol, was charged before the Regional Trial Court of Manila with illegal recruitment (Criminal Case No. 87-57826) for allegedly collecting fees exceeding the POEA-allowed maximum from complainants Lucia Bernardo, Froilan Briones, and Reynaldo Validor. Six other separate informations for estafa were filed against the same individuals and against Gaoat alone. Only Gaoat was arrested and tried. After a joint trial of the consolidated cases, the trial court convicted Gaoat of illegal recruitment in large scale and sentenced her to life imprisonment and a fine. It dismissed three estafa cases and acquitted her of the three other estafa charges. Gaoat appealed her conviction.

ISSUE

Whether the prosecution proved beyond reasonable doubt that Alicia B. Gaoat conspired with her superiors in the crime of illegal recruitment by collecting excessive placement fees.

RULING

No. The Supreme Court reversed the trial court’s decision and acquitted Alicia B. Gaoat. The prosecution evidence failed to adequately show her knowing and willful participation in the illegal acts. The evidence established that Gaoat was merely the cashier of Roan Philippines, Inc., receiving a monthly salary of P1,150.00. Her role was limited to receiving money from complainants as instructed by her superiors, Irons (the President) and Babol (the General Manager), for recording and deposit, in line with her normal duties. There was no proof that she knew the fees collected were excessive, that she negotiated or fixed these fees with the complainants, or that she misappropriated the money. The Court found no clear and convincing evidence of conspiracy between Gaoat and her co-accused. Her act of receiving money in her official capacity as cashier did not constitute an act of recruitment and placement as defined by law. Therefore, her guilt was not proven beyond reasonable doubt.