G.R. No. 197049 - People vs. Rea y Guevarra

Appellants Maria Jenny Rea y Guevarra (Rea) and Estrellita Tendenilla (Tendenilla) were charged with the crime of illegal recruitment committed on a large scale.
The illegal recruitment scheme was alleged to have taken place from June 2005 to August 23, 2005 in Mandaluyong City, involving multiple complainants.
The recruitment was characterized by representations that the accused had the authority to contract, enlist, and transport Filipino workers for employment abroad (specifically for work in London).

Recruitment efforts were executed through coordinated actions between the accused and a third party, Ginette Azul, who, though also involved, remained at large.
Tendenilla purportedly promised employment abroad and collected placement fees ranging from P100,000.00 to P250,000.00 from at least six private complainants.
The scheme involved detailed arrangements, including meetings at travel agency offices, signing of fictitious employment contracts, and promises of job placement in London.

Private complainants met the accused or were referred to them through Ginette Azul, who initially facilitated the contact between the complainants and Tendenilla.
The complainants paid placement fees in installments, with documented transactions such as:

Alvaro Trinidad paying P114,000.00 for job placement in London.
Michael Soriano paying an initial Php70,000.00, followed by another Php30,000.00.
Rebecca Villaluna, Maricel Tumamao, Nyann Pasquito, and Cyrus Chavez also paying significant sums.

Subsequent travel to Thailand and Malaysia was arranged, wherein the complainants were supposed to secure non-immigrant visas to validate their stay while waiting for employment processing.

Represented herself as having the capacity to deploy workers to London, assuring job opportunities and collecting considerable placement fees.
Met complainants during training sessions and personal meetings, and organized travel arrangements to Thailand and Malaysia.

Acted as an assistant or companion (notably described as a babysitter) to Tendenilla and was involved in facilitating the visa processing and travel logistics by accompanying the complainants.
Participated in the later phases of the recruitment process such as escorting complainants to the border and assisting in the visa applications.

The testimonies of the private complainants were consistent and detailed, recounting transactions, interactions, and travel arrangements.
Documentary evidence, including referral letters, affidavits of arrest, sworn statements, and banking records, corroborated the complainants’ accounts.
A certification from the Philippine Overseas Employment Administration confirmed that Tendenilla was not licensed to undertake recruitment activities.

The Regional Trial Court (RTC) convicted the accused based on the evidence showing their engagement in illegal recruitment on a large scale.
The Court of Appeals affirmed the RTC’s judgment, finding all elements of the offense proven beyond reasonable doubt.
On appeal, the accused contested the sufficiency and credibility of the evidence and argued that mere presence during certain phases (especially in Thailand) did not equate to active recruitment; these arguments were rejected by the appellate court.

The accused were found guilty of large scale illegal recruitment, an offense classified as economic sabotage under Republic Act No. 8042.
Penalties imposed included life imprisonment and a fine of Five Hundred Thousand Pesos (P500,000.00) for each accused, as well as orders for indemnification of the defrauded complainants.
The case against Ginette Azul was placed in the archives pending her arrest, with an alias warrant of arrest to be issued.

Whether the evidence, particularly the detailed and consistent testimonies of the private complainants, sufficiently established that the accused conducted unauthorized and fraudulent recruitment activities.
Whether documentary evidence, such as the POEA certification and bank records, adequately corroborated the claims of misrepresentation and unauthorized recruitment.

Whether Tendenilla’s representations and collection of placement fees constituted the execution of illegal recruitment activities.
Whether Rea’s role—assisting in travel arrangements, accompanying complainants, and facilitating visa processing—amounted to active participation in the recruitment scheme or was merely ancillary.

Whether the coordinated actions and concerted efforts of Rea, Tendenilla, and their co-conspirator Ginette Azul established a common purpose and built a case for conspiracy in illegal recruitment.
How the combined actions of the accused, ranging from fee collection to arranging travel logistics, satisfied the elements needed to establish a joint criminal enterprise.

Whether the crime should be classified under large scale illegal recruitment tantamount to economic sabotage under Section 7(b) of Republic Act No. 8042.
Whether the penalties imposed—life imprisonment and a hefty fine—appropriately matched the gravity of the offense given the scale of the recruitment scheme.