Title
People vs. Gutierrez y Timod
Case
G.R. No. 124439
Decision Date
Feb 5, 2004
Accused Flor Gutierrez, unlicensed, recruited multiple individuals for overseas jobs, collected fees, and failed to deploy them, leading to a conviction for Illegal Recruitment in Large Scale.

Case Summary (G.R. No. 124439)

Facts of the Case

The Regional Trial Court (RTC) of Pasay City, Branch 108, rendered its judgment on March 22, 1996, finding Flor Gutierrez guilty of illegal recruitment in large scale. The court imposed a sentence of life imprisonment and a fine of PHP 100,000.00. Throughout the recruitment period, Gutierrez, acting in concert with others, solicited complainants for overseas job positions, particularly as domestic helpers in Dubai, without the necessary license from the Philippine Overseas Employment Administration (POEA).

Recruitment Process Description

The recruitment process began when complainants approached individuals believed to be agents of Gutierrez. Each complainant was instructed to submit various documents and pay significant fees that cumulatively amounted to thousands of pesos, purportedly for processing their overseas employment. Many complainants claimed that despite fulfilling these financial obligations, their promised departures to Dubai never occurred.

Evidence Gathered

The prosecution presented testimonies from the complainants detailing their experiences, including fees paid to agents, submission of documents, and false promises of employment. The complainants’ accounts revealed a pattern of exploitation, where they were misled about their job status and fees demanded repeatedly. Eventually, the complainants sought redress from authorities upon learning that Gutierrez lacked a valid recruitment license.

Arrest and Defense Claims

The arrest of Gutierrez was executed during an entrapment operation where marked money was exchanged. In her defense, Gutierrez claimed she was an employee of a licensed recruitment agency and not personally liable for illegal recruitment. She produced documents that indicated her employment at a licensed agency and asserted that her activities were in the scope of her assigned duties.

Court's Findings

The RTC concluded that Gutierrez’s defense was insufficient. It maintained that illegal recruitment requires the absence of a valid license and that the act of soliciting applicants for overseas employment inherently qualifies as illegal. The court emphasized the absence of authorization from the POEA, highlighting that mere employment at a licensed agency does not absolve her of responsibility if she engaged in unlicensed recruitment activities.

Affirmation of the Conviction

In the appeal, the court reiterated

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