Case Digest (G.R. No. 91896)
Facts:
Aurora T. Aquino v. Court of Appeals and People of the Philippines, G.R. No. 91896, November 21, 1991, Supreme Court Third Division, Gutierrez, Jr., J., writing for the Court. Petitioner Aurora T. Aquino was criminally charged by information filed November 2, 1978, in the Regional Trial Court of Manila, Branch VIII, with illegal recruitment allegedly committed between May 23, 1974 and May 1975, in violation of Article 25 (the Court treated the charge as under Article 24) of Presidential Decree No. 442 (the Labor Code). Upon arraignment she pleaded not guilty and trial ensued.The prosecution presented several complainants who testified they applied for employment in Guam in 1973 and paid recruitment fees (generally P1,500 each); some received partial refunds and one “group” refund check for P5,270 was alleged to have been issued but dishonored for lack of funds. The key factual dispute was whether recruitment and related collections occurred after petitioner’s license expired on May 18, 1974. Petitioner testified she was a licensed labor contractor (license dated May 22, 1973), acted as representative for overseas employers, sought renewal after expiration, wound up operations after May 18, 1974, and issued checks to refund applicants.
The RTC found petitioner guilty of illegal recruitment (penalized under Art. 39 par. (b), Labor Code), sentenced her to indeterminate imprisonment of four to seven years, fined P20,000, and ordered indemnification of the complainants in the total amount of P5,270 with interest. The petitioner appealed to the Court of Appeals, which on November 15, 1989 affirmed the RTC’s conviction in toto. Petitioner sought relief in the Supreme Court by petition for review; this Court initially denied the pe...(Subscriber-Only)
Issues:
- Did the Regional Trial Court of Manila have jurisdiction over the criminal information, and may petitioner now question that jurisdiction?
- Did petitioner commit illegal recruitment by receiving payments after her license expired on May 18, 1974?
- If petitioner is liable, was the trial court’s order that she indemnify the complainants in the t...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)