Facts:

The case revolves around Thelma Reyes (accused-appellant) and her husband Nick Reyes (accused, at large), who faced charges of illegal recruitment under Article 38 of Presidential Decree No. 442. The events took place in 1985 and 1986, primarily in Los Baños, Laguna. The prosecution stemmed from a complaint filed by two main witnesses, Rosalino Bitang and Fabian Baradas, along with others who claimed to be victims of the Reyes couple's illegal activities. They testified that they went to the Reyes home to apply for employment abroad and were required to make substantial payments. Bitang initially paid P5,000 to Nick Reyes as a downpayment, and subsequently, they paid an additional P34,000 and P6,000 to the couple for what they believed were recruitment fees. In total, Bitang and Baradas collectively offered significant sums, believing they would secure overseas jobs promised by the Reyes couple. Bitang later discovered through the Philippine Overseas Employment Administratio

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Facts:

Background of the Case

• The case involves the prosecution of Thelma Reyes for illegal recruitment under Article 38, P.D. No. 442, as amended.
• The charge stemmed from transactions wherein money was collected from job applicants for overseas employment—a recruitment activity later found to be illegal.
• Thelma Reyes was tried in the Regional Trial Court of Laguna, Branch 35, while her husband, Nick Reyes, who was implicated in the transactions, remained at large.

Proceedings and Witness Testimonies

• Testimonies of the complainants, notably Rosalino Bitang and Fabian Baradas, formed the centerpiece of the prosecution’s evidence.
• Bitang testified that in 1985 he, along with five companions, went to the Reyes’ house in Los Banos, Laguna, to seek employment abroad.
• He recounted giving P5,000 to Nick Reyes as a downpayment, who then passed the amount to his wife, with a receipt issued by Nick Reyes (Exh. A).
• Further testimony by Bitang detailed another payment of P34,000 made on January 14, 1986.
• Of this amount, P8,500 was on behalf of Bitang’s own placement fee while the rest covered fees for his companions.
• The receipt (Exh. B) was again issued solely by Nick Reyes, establishing the flow of money through him to Thelma Reyes.
• Fabian Baradas also testified that he met Thelma Reyes during her recruitment activities in Lemery, Batangas.
• He identified several occasions between September and December 1985 when he, along with other job applicants, visited the Reyes’ rented house in Los Banos.
• Baradas confirmed multiple payments, including a P6,000 payment evidenced by a receipt (Exh. E) and an additional P12,000 payment on January 14, 1986.
• Both complainants later discovered, via a certification from the Philippine Overseas Employment Administration (POEA), that the Reyes were not licensed recruiters.
• In her defense, Thelma Reyes claimed that she had little to do with recruitment activities, asserting that she only met the complainants after her husband had initiated contacts.
• She contended she was estranged from her husband, who conducted the recruitment and even issued the receipts.
• She argued that her dissociation from her husband’s illegal activities was demonstrated by their separation since March 1986.
• The defense further stressed that she had not actively engaged in the collection or handling of money for recruitment.

Documentary Evidence and Admissions

• The documentary evidence comprised receipts (Exh. A, B, and E) issued by Nick Reyes that recorded monetary transactions from the complainants.
• These documents indicated that money was collected and then handed over to Thelma Reyes, who purportedly counted the funds.
• Despite the receipts being solely signed by Nick Reyes, the complainants testified that they had dealt with both him and his wife, and that the funds were disbursed by the couple in the guise of facilitating employment abroad.

Trial Court’s Findings and Judgment

• The trial court found that the evidence, including both testimonies and documentary receipts, established beyond reasonable doubt Thelma Reyes’ active participation in illegal recruitment.
• Initially, the accused was sentenced to suffer Reclusion Perpetua, pay fines, and indemnify the complainants.
• The trial court’s decision on the basis of the evidence later became the subject of appellate scrutiny.

Issue:

Sufficiency and Credibility of Testimonial Evidence

• Whether the testimonies of complainants Bitang and Baradas, despite being self-serving, were sufficient and credible to sustain a conviction for illegal recruitment.
• Whether reliance on the testimony of a single complainant or a limited number of witnesses, when supported by documentary evidence, meets the standard of proof beyond reasonable doubt.

Interpretation and Application of the Receipts

• Whether the documentary receipts—which were signed solely by Nick Reyes and did not specify the purpose of the payment—could conclusively tie Thelma Reyes to the illegal recruitment scheme.
• Whether the flow of money, as evidenced by the receipts and their accompanying testimonies, is enough to impute participation in the crime to both spouses.

Qualification of the Offense as Illegal Recruitment on a Large Scale

• Whether the recruitment conducted by the Reyes’ fits within the “large scale” definition under Article 38(b) of the Labor Code, which requires that the recruitment involve three or more persons.
• Whether additional cases and pending charges can be cumulatively considered to establish large scale recruitment or if only the individual transactions in this information should be considered.

Adequacy of Evidence Concerning the Involvement of a Syndicate

• Whether there was sufficient evidence to establish that both Thelma Reyes and her husband acted in concert as a syndicate or that their conduct amounted to economic sabotage as defined by law.
• The impact of the absence of testimony from certain persons, such as Dionisio de Castro, on the overall credibility of the prosecution’s case.

Ruling:

• (Subscriber-Only)

Ratio:

• (Subscriber-Only)

Doctrine:

• (Subscriber-Only)