G.R. No. 108027 . March 4, 1999.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. CRISTINA M. HERNANDEZ, accused-appellant.

FACTS

Accused-appellant Cristina Hernandez was charged with Illegal Recruitment in Large Scale. The Information alleged that from January to March 1986, in Manila, she conspired with others to recruit and promise employment abroad to numerous individuals, including Ferdinand Calara, Pedro Bonifacio, Ernesto Cruz, and Luisito Mariñas, without the requisite license from the Department of Labor and Employment. The prosecution presented these four witnesses, who testified that they were introduced to Hernandez as the owner of Min-Asia Management Services. They paid various processing fees and submitted documents based on promises of deployment to Saudi Arabia, but no employment materialized. Mariñas was even issued a bouncing check when he sought a refund.
The defense presented Hernandez as its sole witness. She claimed she was merely a sub-lessor of office space to Min-Asia and was engaged in a retail chicken business, denying any connection to the recruitment agency, any knowledge of the complainants, and any participation in recruitment activities. She asserted that her signatures on prosecution exhibits were forgeries.

ISSUE

Whether the prosecution proved beyond reasonable doubt that accused-appellant Cristina Hernandez is guilty of Illegal Recruitment in Large Scale.

RULING

Yes. The Supreme Court affirmed the conviction. The legal logic centered on the elements of illegal recruitment and the credibility of witnesses. For illegal recruitment in large scale, the prosecution must prove that (1) the accused undertook recruitment activities without the necessary license or authority, and (2) the accused committed the same against three or more persons individually or as a group. The testimonies of the four private complainants, which were found credible and consistent by the trial court, positively established that Hernandez represented herself as having the power to deploy workers abroad, collected fees, and required the submission of documents—all acts constitutive of recruitment and placement under the Labor Code. Her defense of denial and alibi was deemed inherently weak and could not overcome the positive identification and detailed accounts of the victims. The crime, involving three or more persons, constitutes large scale illegal recruitment, a non-bailable offense punishable by life imprisonment. The Court corrected the penalty, stating it should be reclusion perpetua, not “life imprisonment,” as they are distinct penalties under Philippine law. The award of indemnity to the victims was sustained.