G.R. No. 214340 - People vs. AbellaNo.

The case involves the People of the Philippines as the plaintiff-appellee and Gilda Abellanosa as the accused-appellant.
The charge is illegal recruitment in large scale under Section 6(m) in relation to Section 7 of Republic Act No. 8042 (Migrant Workers and Overseas Filipinos Act of 1995).

The appellant was charged in several criminal cases (Nos. 47984, 47985, 47987, 47988, 47989, 47990, and 47991) for engaging in recruitment activities without the requisite license or authority.
In Criminal Case No. 47984, it was alleged that on February 15, 1997, in the Municipality of Pavia, Iloilo, the appellant, falsely representing herself as a recruiter for overseas employment in Brunei, collected processing fees from applicants without having secured authority from the proper government agency.
Similar details were replicated in the seven Informations with variations only in the date of commission, names of private complainants, and the amounts collected.

Timogen O. Pastolero – testified she approached the appellant at Shirley Taberna’s house, received a processing fee of P5,500.00, and was promised deployment to Brunei.
Zeno M. Cathedral – testified he paid P20,000.00 after being convinced of the appellant’s credentials, only to later find his passport details unchanged.
Cecilia L. Orias – testified that she paid placement fees (initially P10,000.00 out of a P25,000.00 requirement) with assurances of deployment.
Janet P. Suobiron – testified about paying a partial placement fee with a handwritten note in lieu of a formal receipt.
Nenita T. Bueron – testified that after payment of P5,000.00, she was informed that her papers were not processed due to expiration.
Elsie P. Pelipog – testified that she paid P12,500.00 and was met with evasive responses when requesting a receipt.

The documentary evidence includes a job order, calling card, and the absence of receipts for the payments collected, all corroborating the testimony that the appellant represented herself as an authorized recruiter to commit the offense.

The appellant denied ever having met any of the private complainants during her brief stay in Iloilo.
She claimed that her visit was solely to assist Shirley in processing a business license, not to recruit workers.
The defense ascribed the recruitment activities to Shirley, not to the appellant herself.

The Regional Trial Court (RTC) of Iloilo City, Branch 38 rendered its decision on September 9, 2002, finding the appellant guilty beyond reasonable doubt in all cases except Criminal Case No. 47986 (insufficient evidence).
The RTC imposed life imprisonment and a fine of P500,000.00 for each of the applicable cases, along with an order to reimburse the complainants the exact amounts they paid.
On March 19, 2014, the Court of Appeals (CA) affirmed the RTC decision, maintaining the conviction and penalties imposed against the appellant.

The appellant elevated her case to the Supreme Court after the CA affirmed the RTC decision.
Both parties waived the filing of supplemental briefs after the Court requested their submission.
The main contention on appeal centered on whether the trial court erred in finding her guilt beyond reasonable doubt, with the appellant maintaining that she had no role in the recruitment process.

Whether the trial court erred in finding that the appellant’s guilt for illegal recruitment in large scale was proven beyond reasonable doubt.

The appellant contended she never met the complainants and that her presence in Iloilo was for an entirely different purpose.
The defense argued that responsibility for the recruitment activities rested with Shirley, not with the appellant.

Whether the recruitment activities—affecting seven private complainants—qualify as “illegal recruitment in large scale” under RA 8042.
Whether the imposition of penalties (life imprisonment and fines) should be levied per individual case or collectively given the nature of the offense.