Title
People vs. Villas y Nique
Case
G.R. No. 112180
Decision Date
Aug 15, 1997
Accused recruited four individuals for overseas jobs without DOLE license, collected fees, and was convicted of illegal recruitment in large scale; Supreme Court affirmed life imprisonment and fines.
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Case Summary (G.R. No. 112180)

Appeal Overview

  • The case involves an appeal from the Regional Trial Court of Davao City, which found Mildred Villas guilty of illegal recruitment in large scale.
  • The trial court imposed a penalty of life imprisonment on Villas.
  • The appellant contended that the prosecution's evidence was insufficient for conviction.
  • The Supreme Court ruled that the appeal was not meritorious, affirming the trial court's decision.

Elements of Illegal Recruitment

  • Illegal recruitment in large scale is defined under Article 38 of the Labor Code.
  • Recruitment and placement include any act of canvassing, enlisting, contracting, transporting, utilizing, hiring, or procuring workers.
  • The elements of illegal recruitment in large scale are:
    1. The accused undertook recruitment activities or prohibited practices.
    2. The accused lacked the necessary license or authority.
    3. The crime was committed against three or more persons.

Recruitment Activities Established

  • The appellant informed complainants that she was recruiting nurses for employment in Canada and explained the application process.
  • Complainants submitted application papers and initial fees, indicating recruitment activities.
  • The absence of receipts does not negate the prosecution's case for illegal recruitment.

Lack of Authority to Recruit

  • Testimony from the head of the Philippine Overseas Employment Administration confirmed that Villas had no authority to recruit.
  • The appellant did not contest the admissibility of this evidence.

Multiple Victims

  • Four complainants testified that they were misled by Villas into believing she had the authority to recruit for employment in Canada.
  • Their testimonies were deemed credible and sufficient to classify the crime as illegal recruitment in large scale.

Denials vs. Positive Testimonies

  • The appellant's denials were found unpersuasive and self-serving, lacking substantiation.
  • Positive testimonies from credible witnesses outweighed the appellant's claims.

Credibility of Witnesses

  • The trial court's findings regarding witness credibility were respected, as it had the advantage of observing their demeanor during testimony.
  • The court noted that it is unlikely for strangers to conspire to falsely accuse someone of a serious crime.

Assessment of Prosecution Evidence

  • The appellant's arguments regarding the insufficiency of evidence were rejected.
  • The prosecution's case was supported by credible...continue reading

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