G.R. No. 244001 - Marajas vs. People

Petitioner Aquilina M. Marajas and co-accused Myrna Melgarejo were charged before the Regional Trial Court (RTC) of Pasay City, Branch 111, for Illegal Recruitment under Section 6 of Republic Act (R.A.) No. 8042, as amended by R.A. No. 10022.
Petitioner Marajas, Melgarejo, and co-accused Raymond Marquez Pilac were also charged for violation of Section 5(e) of R.A. No. 9208, the Anti-Trafficking in Persons Act of 2003.

Marajas and Melgarejo, non-licensees and without authority to deploy Filipino workers abroad, were accused of referring Nieves Tag-at for employment in Beijing, China, and facilitating her departure through falsified travel documents.
Melgarejo allegedly directed Marajas to facilitate Tag-at’s departure by instructing her to fall in line with Pilac, who then cleared Tag-at despite her inability to financially support her travel.

Tag-at sought employment through Myron Travel Agency, owned by Melgarejo. Petitioner allegedly represented herself as authorized to arrange for a sponsor in Beijing for Tag-at.
Marajas gave Tag-at a forged Letter of Invitation and Support and travel documents purportedly signed by a Johnelyn Daquigan.
Petitioner accompanied Tag-at to Ninoy Aquino International Airport (NAIA) Terminal 3 on May 31, 2012, where she instructed Tag-at to fall in line at the immigration counter manned by Pilac.
Immigration and Inter-Agency Council Against Trafficking (IACAT) agents overheard petitioner’s instructions and subsequently conducted secondary inspection, finding the documents counterfeit.
Tag-at admitted, during investigation, that she was misled into believing she was going to work in Beijing, initially as a tourist, and that the invitation letter and birth certificate provided were fake.
Petitioner's lack of license to recruit workers was certified by the Philippine Overseas Employment Agency (POEA).

Petitioner denied involvement in recruitment or illegal acts, claiming she only met Tag-at as a fellow applicant at Myron Travel Agency.
Petitioner stated she accompanied Tag-at to the airport only to verify the legitimacy of the agency and was unaware of any fraudulent acts or offloading.
Petitioner denied knowledge of any falsified documents and claimed she left once Tag-at was subjected to secondary inspection.

The RTC found petitioner guilty of Illegal Recruitment and violation of R.A. No. 9208, sentencing her to imprisonment and fines as mandated by law.

The CA affirmed with modification the RTC’s findings, increasing the penalty for Illegal Recruitment and maintaining the conviction for Trafficking in Persons.
The CA ruled the prosecution presented sufficient evidence of all elements of the crimes charged.

Petitioner filed a Petition for Review on Certiorari before the Supreme Court, arguing insufficient evidence and denying recruitment activity or facilitation of travel with fraudulent documents.
Petitioner claimed Tag-at was coerced to give false testimony and challenged the credibility of the prosecution witnesses.

Whether the Court of Appeals gravely erred in finding petitioner guilty of Illegal Recruitment under Section 6 of R.A. No. 8042, as amended by R.A. No. 10022.
Whether the Court of Appeals gravely erred in finding petitioner guilty of Trafficking in Persons under Section 5(e) of R.A. No. 9208.