Title
People vs. Bodozo y Bula
Case
G.R. No. 96621
Decision Date
Oct 21, 1992
Joey and Nimfa Bodozo were sentenced to life imprisonment and fined P100,000 for illegal recruitment, as they promised overseas employment without the required license.
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Case Digest (G.R. No. 96621)

Facts:

  • Joey Bodozo y Bula and Nimfa Bodozo y Neri, a married couple, were accused of illegal recruitment.
  • The events occurred between October 3, 1988, and April 8, 1989, in Manila, Philippines.
  • They were charged under Article 38 of the Labor Code and found guilty by the Regional Trial Court, National Capital Judicial Region, Branch XLIX, in Criminal Case Nos. 89-73608-SCC to 89-73613-SCC.
  • The prosecution claimed the couple misrepresented their ability to recruit and transport Filipino workers for overseas employment without a license from the Department of Labor and Employment.
  • They allegedly recruited five individuals, promising jobs in Saudi Arabia and Singapore for a fee.
  • The accused demanded various amounts for processing fees, issued receipts for some payments, but not for others.
  • The trial court acquitted them of five counts of estafa but convicted them of illegal recruitment, sentencing each to life imprisonment and a fine of P100,000.
  • The accused appealed, arguing they only assisted the complainants in job applications and that the prosecution did not prove their guilt beyond a reasonable doubt.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court affirmed the Regional Trial Court's decision, finding the accused guilty of illegal recruitment.
  • The court upheld the life impris...(Unlock)

Ratio:

  • The Supreme Court stated that illegal recruitment, as defined under Article 38 of the Labor Code, requires the offender to be a non-licensee or non-holder of authority for recruitment activities.
  • The court found that the accused were neither licensed nor authorized to recruit workers, supported by a certification from the Philippine Overseas Employment Administration (POEA).
  • The actions of the accused, such as collecting fees, requiring documents (NBI clearances, medical certificat...continue reading

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