Case Digest (G.R. No. 108027)
Facts:
People of the Philippines v. Cristina M. Hernandez, G.R. No. 108027, March 04, 1999, Supreme Court Second Division, Quisumbing, J., writing for the Court.The information charged accused-appellant Cristina M. Hernandez, together with several co-accused, with illegal recruitment committed in large scale in violation of Articles 38(a) and (b), Article 39(a), and Article 13(b) and (c) of the Labor Code (PD 442 as amended). The complaint alleged that between January and March 1986 Hernandez and others, for a fee, recruited and promised overseas employment to multiple applicants without the required DOLE license. The information named specific applicants as victims.
On March 31, 1989, Hernandez and co-accused Mendez were arraigned and pleaded not guilty. At trial the prosecution presented four witnesses — Ferdinand Calara, Pedro Bonifacio, Ernesto Cruz and Luisito Marinas — who testified that they were introduced to the recruitment agency Min-Asia and to Hernandez (described by witnesses as the owner or an officer), paid placement and agent fees, submitted documentary requirements, and were promised deployment to jobs (including positions at ARAMCO). Receipts, application forms and related documents and a bounced check were admitted in evidence.
The defense put Hernandez as its lone witness. She testified she merely sub-leased part of her office space at the Don Santiago Building to Min-Asia, denied being an officer, stockholder or recruiter for Min-Asia, denied signing the documents, and claimed she had no personal connection with the complainants aside from proximity.
The Regional Trial Court, Branch 12, Manila, found the accused’s denials unconvincing, credited the prosecution witnesses and documentary exhibits, and convicted Hernandez and Mendez of illegal recruitment in large scale. The trial court sentenced them — in its dispositive paragraph — to “life imprisonment (RECLUSION PERPETUA)” and a fine of P100,000, ordered restitution to the complainants, and imposed costs. Records were forwarded to the Sup...(Subscriber-Only)
Issues:
- Did the trial court err in finding the accused guilty beyond reasonable doubt based on the prosecution’s evidence despite the accused’s denial?
- Was the penalty imposed by the trial court correctly stated as “reclusion perpetua” or should ...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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