G.R. No. 128280 - People vs. Chua

On October 5, 1993, Assistant City Prosecutor Leocadio H. Ramos, Jr. filed an information before the Regional Trial Court (RTC), Manila, Branch V, against Alicia A. Chua for illegal recruitment in large scale, for recruiting and promising employment abroad without a license from the Department of Labor.
The illegal recruitment charge involved several complainants who paid placement fees for supposed jobs abroad arranged by accused Chua.
On the same date, nine additional criminal cases were filed against Chua for estafa, each involving individuals who were defrauded of placement fees ranging from P11,000 to P15,000, obtained through false promises of employment and recruitment services in Taiwan.

Accused Chua represented herself as having the authority to recruit workers for overseas employment but lacked the required license.
She collected placement fees from the complainants on the promise to facilitate their employment abroad.
Chua later failed to deploy the complainants or reimburse the fees, subsequently avoiding contact with them.

The cases were consolidated and tried jointly.
Evidence showed that Chua received a facsimile from Harmony Electronics Company, a Taiwanese firm, requesting her to coordinate with certain individuals for employment opportunities in Taiwan.
Chua told complainants she could send them abroad for a fee, required them to secure NBI clearances and medical certificates, and accepted fees amounting to P15,000 each.
Despite assurances, complainants were not deployed and Chua eventually went into hiding.
Investigations by the Philippine Overseas Employment Agency (POEA) revealed that Chua was not licensed to recruit workers overseas.

On October 3, 1995, the RTC found Chua guilty beyond reasonable doubt of illegal recruitment in large scale and eight counts of estafa, sentencing her to life imprisonment and fines, including restitution to the complainants.
One estafa case was dismissed due to failure of the prosecution to present evidence.

Her later approval for a license to recruit (dated April 13, 1993) should validate her recruitment activities prior to that date.
She was denied her constitutional right to compulsory process, specifically the production of POEA records to challenge the prosecution's evidence.

Whether the approval of accused-appellant’s recruitment license application, dated after the commission of the offenses, can retroactively legalize her prior recruitment activities.

Whether the accused-appellant’s constitutional right to compulsory process was violated due to the trial court’s refusal to compel the production of POEA records.