Case Digest (G.R. No. 114905)
Facts:
People of the Philippines v. Donnie Peralta y Picana, G.R. No. 114905, December 12, 1997, Supreme Court Third Division, Panganiban, J., writing for the Court.
The plaintiff-appellee is the People of the Philippines; the accused-appellant is Donnie Peralta y Picana. An Information dated April 28, 1993 (docketed as Criminal Case No. 93-3651) charged Peralta with illegal recruitment in violation of Section 1, PD No. 2018, amending Article 38 of PD 442, as amended (Labor Code). At arraignment on July 12, 1993 Peralta pleaded not guilty; at pre-trial he admitted he was not licensed or authorized by the Philippine Overseas Employment Administration (POEA) to recruit for overseas employment.
The case was tried before the Regional Trial Court of Makati, Branch 132 (presided by Judge Herminio I. Benito). The prosecution presented four complainants — Rene Alcaraz, Imelda Aguirre, Julius Navarro and Maria Teresa Magdaraog — who testified that Peralta represented himself as able to procure jobs in Taiwan, issued referral slips for medical examinations, and collected processing/placement fees (generally P10,000; Aguirre paid P9,000). Documentary exhibits included referral/request forms signed by Peralta and receipts signed by his wife Marie Peralta or stepdaughter Maila Mercado; the referral forms bore dates (April–September 1992) preceding the date Peralta later claimed he began employment with the recruiting firm.
Peralta's defense was that he was an employee (a messenger) of Sons and Daughters Travel Consultancy managed by his second wife, Marie Peralta, and that receipts were issued by his wife or stepdaughter; he denied personally receiving the fees or recruiting on his own. He testified he only began working for the firm in October 1992. Defense witness Celedonio Munar testified some applicants paid placement fees to Marie Peralta and that Marie eventually refunded one complainant.
The trial court found Peralta guilty beyond reasonable doubt of illegal recruitment in large scale under Articles 38 and 39 of the Labor Code and, on January 10, 1994, sentenced him to life imprisonment plus a P100,000 fine. The court credited the complainants' accounts, gave weight to the referral slips and receipts bearing Peralta's signature or con...(Pro-only)
Issues:
- Was Peralta prosecuted and convicted as a recruiter acting in his own capacity rather than as an employee or agent of Sons and Daughters Travel Consultancy?
- Did the prosecution present sufficient evidence to prove Peralta guilty beyond reasonable doubt of illegal recrui...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
- (Pro-only)