Facts:

The case involves Mildred Villas y Nique, the accused-appellant, who was charged with illegal recruitment in large scale under the Labor Code of the Philippines. The events leading to the case unfolded between November 1990 and April 1991 in Davao City, where Villas allegedly misrepresented herself as a recruiter for employment abroad, specifically in Canada. The Second Assistant City Prosecutor, Calixto A. Esparagoza, filed an Information against her on April 18, 1991, stating that Villas unlawfully recruited and promised job placements to four individuals—Alfonsa Acierda, Teresita Caballero-Villegas, Nenita Balisalisa, and Ligaya Rentura—without the necessary license from the Department of Labor and Employment (DOLE).

During the trial, the prosecution presented eight witnesses, including the four complainants, who testified about their interactions with Villas. They recounted how Villas required them to submit application letters, birth certificates, photographs, and pro...

Facts:

Parties Involved:

• Plaintiff-Appellee: People of the Philippines.
• Accused-Appellant: Mildred Villas y Nique.

Charge:
Accused-appellant was charged with illegal recruitment in large scale under Articles 38(a) and 38(b) in relation to Article 39 of the Labor Code, as amended, for recruiting and promising employment abroad to four individuals without a license from the Department of Labor and Employment (DOLE).

Prosecution’s Version:

1. Recruitment Scheme: In November 1990, appellant falsely represented herself as authorized to recruit nurses and nanny-housekeepers for Canada.
2. Complainants:
   • Alfonsa Acierda Mortos: Paid $200 initially and later P6,000 after receiving her case number. Total: P11,300.
   • Teresita Caballero Villegas: Paid $200 initially and later P5,800 after receiving her case number. Total: P11,800.
   • Nenita Balisalisa: Paid an initial P5,800 but failed to pay the balance. Total: P6,200.
   • Ligaya Rentura: Paid P2,000 as a down payment.
3. Discovery: The scheme was uncovered when Teresita Quitoriano, a fellow nurse, applied directly to the Canadian Immigration Assistance Service (CIAS) without paying fees.
4. Entrapment: With the assistance of the National Bureau of Investigation (NBI), appellant was entrapped after receiving marked money from complainants.

Defense’s Version:

1. Appellant’s Denial: Mildred Villas denied recruiting anyone or accepting payments. She claimed she only provided information on how to apply for jobs in Canada.
2. Corroboration: Vilma Luyahan, a defense witness, supported appellant’s claims.

Trial Court’s Decision:
The Regional Trial Court of Davao City found the accused guilty of illegal recruitment in large scale and sentenced her to life imprisonment, a fine of P100,000, and ordered her to indemnify the complainants.

Issue:

• (Unlock)

Ruling:

• (Unlock)

Ratio:

1. Elements of Illegal Recruitment in Large Scale:

   • First Element: The accused undertook recruitment activities without authority. Appellant clearly engaged in recruitment activities by promising employment, collecting fees, and requiring applicants to submit documents.
   • Second Element: The accused lacked a license or authority to recruit. The Philippine Overseas Employment Administration (POEA) certified that appellant had no authority to recruit workers.
   • Third Element: The crime was committed against three or more persons. Four complainants testified that appellant recruited them and collected fees.

2. Credibility of Witnesses:

   • The trial court found the testimonies of the prosecution witnesses credible, consistent, and corroborated by evidence.
   • Denials by the accused, unsupported by clear evidence, were deemed insufficient to overturn the conviction.

3. Absence of Receipts:

   • The Court ruled that the absence of receipts does not exonerate the accused. Testimonies of witnesses are sufficient to prove payment in illegal recruitment cases.

4. Trial Court’s Findings:

   • Appellate courts generally defer to the trial court’s assessment of witness credibility, as it has the advantage of observing the witnesses firsthand.