G.R. No. 226140 - People vs. Rios y Catagbui

The case involves accused-appellant Isabel Rios y Catagbui, who, as president and general manager of Green Pastures International Staffing Incorporated, was charged with violations of the Migrant Workers and Overseas Filipinos Act of 1995 (RA 8042) and the Revised Penal Code (RPC).
The prosecution charged Rios on two counts:

Illegal Recruitment – particularly under Section 6(m) of RA 8042, which penalizes the failure to reimburse documentation and processing expenses when deployment does not occur without the worker’s fault, and as such, when committed in large scale (against three or more persons).
Estafa (Swindling) – under Article 315(2)(a) of the RPC, which requires the use of fraudulent means or false pretenses executed prior to or at the time of the fraud.

The Information detailed that from July 2007 to December 2008, at the Green Pastures office located initially at J. Wardley Building in Pasay City, the accused—together with co-accused Anna Espiritu and Ellen Mabborang—engaged in recruitment activities.
The acts included:

Promising deployment abroad for employment, specifically to Taiwan and Singapore.
Receiving various amounts as placement and documentation fees from several private complainants.
Failing to deploy the complainants for work, despite collecting the fees.
Not reimbursing the funds paid by complainants for processing and documentation when deployment did not occur, thus constituting illegal recruitment in large scale.

Prior to trial on the merits, Rios submitted a Confession of Judgment on the civil aspect for the Estafa cases with respect to some complainants (Tiglao, Dacillo, Milanes, Papio, Custodio), admitting that certain amounts were received by the agency.
The private complainants, through their testimonies, explained that:

They paid substantial placement fees, sometimes in installments, to an agent (Ellen Mabborang) or directly through transactions facilitated by the agency.
They were promised scheduled departures but experienced delays, repeated additional demands (e.g., for further medical examinations or processing), and ultimately non-deployment.
In some instances, no official receipts were issued by the agency, although witness testimony served to corroborate the fact of their payments.

Asserts that Rios, as the head of Green Pastures, was in charge of recruitment operations that enticed the complainants to pay fees with the assurance of overseas deployment.
Emphasized the agency’s failure to perform its contractual obligations (deployment) and to reimburse monies when deployment did not occur.

Contended that Rios did not directly transact with some private complainants.
Claimed that the failure to deploy was primarily due to external factors—namely, economic problems in Taiwan that led employers to cease hiring—and not an act of wrongful deception.
Argued that there was no evidence to establish a conspiracy with her co-accused and questioned the validity of the Confession of Judgment.

Whether the evidence adduced by the prosecution established beyond reasonable doubt that Rios, as head of Green Pastures, committed illegal recruitment by failing to reimburse documentation and processing expenses when deployment did not occur without the complainants’ fault.
Whether the elements of Estafa, specifically the fraudulent representations regarding capability and authority to deploy workers abroad, were proven, given that Green Pastures was a duly licensed agency with valid job orders.
Whether the absence of independent evidence from the Department of Labor and Employment (DOLE) to account for the non-deployment of applicants under Section 6(l) of RA 8042 affected Rios’ liability under that provision.
Whether Rios can be held personally liable for the acts of a corporate recruiting agency, based on the principle that corporate officers controlling the business may be held liable when the law specifies personal accountability for corporate actions.