People of the Philippines vs. Lourdes Valenciano y Dacuba (Illegal Recruitment in Large Scale)
### Facts:
In May 1996, Lourdes Valenciano, who claimed to be an employee of Middle East International Manpower Resources, Inc., along with Susie Caraeg, recruited Agapito De Luna for a job in Taiwan. Valenciano required PhP 70,000 as the placement fee and De Luna made three payments at her residence: PhP 20,000 on June 21, 1996; PhP 20,000 on July 12, 1996; and PhP 30,000 on August 21, 1996. This money was handed over to Teresita and Rodante Imperial who issued receipts.
Valenciano, along with Euziel N. Dela Cuesta and Eusebio T. Candelaria, visited Allan De Villa’s house in May 1996 and similarly solicited PhP 70,000 for the same job in Taiwan. De Villa made four payments: PhP 20,000 on May 16, 1996; PhP 20,000 on May 30, 1996; PhP 20,000 on July 8, 1996; and PhP 10,000 on August 14, 1996. These payments were also turned over to Teresita and Rodante Imperial.
Valenciano also went to Euziel N. Dela Cuesta’s house on May 20, 1996, recruiting under similar terms. Dela Cuesta paid PhP 20,000 on May 20, 1996; PhP 20,000 on May 30, 1996; PhP 15,000 on August 12, 1996; and PhP 7,000 on August 21, 1996, all of which were handed over to Teresita and Rodante Imperial.
In another incident on May 1, 1996, Valenciano recruited Eusebio T. Candelaria in Lian, Batangas. Candelaria made the following payments: PhP 20,000 on May 30, 1996; PhP 20,000 on June 24, 1996; and PhP 29,000 on July 17, 1996. These payments were also managed by Teresita and Rodante Imperial.
After receiving payments, Valenciano took the recruited workers to the office of Middle East International Manpower Resources, Inc., in Pasay City, where they filled out application forms.
Due to failure to secure employment for the complainants, Valenciano, Rodante, Teresita, and Rommel Imperial were charged with illegal recruitment in large scale.
At the trial, Valenciano entered a plea of not guilty and the three other accused remained at large. The RTC found Valenciano guilty and sentenced her to life imprisonment and fined her PhP 100,000. Valenciano indemnified the complainants: Agapito R. De Luna (PhP 70,000); Allan Ilagan de Villa (PhP 70,000); Euziel N. dela Cuesta (PhP 62,000); and Eusebio T. Candelaria (PhP 69,000).
Valenciano appealed to the Court of Appeals (CA), which upheld the RTC’s decision. This led to her current appeal before the Supreme Court.
### Issues:
1. **Whether the trial court erred in not acquitting the accused on the basis of reasonable doubt.**
2. **Whether the trial court erred in holding that a conspiracy existed between the accused and her co-accused.**
### Court’s Decision:
**Issue 1: Proof Beyond Reasonable Doubt**
– **Decision:** The Court found sufficient proof against Valenciano, affirming her guilt beyond reasonable doubt. The testimonies of the complainants were credible, pointing to her active involvement in recruitment and receiving payments. Moreover, her defense that she was just following orders in good faith was invalid, illegal recruitment being malum prohibitum, which does not accept good faith as a defense.
**Issue 2: Conspiracy**
– **Decision:** The Court ruled that a conspiracy was established. Valenciano, together with her co-accused, engaged in concerted actions to recruit and receive fees fraudulently. Evidence showed that she not only recruited but also took significant steps to assure the applicants of employment abroad, thus displaying a common design among her and her co-accused.
### Doctrine:
This case reiterates the principle that illegal recruitment involving economic sabotage is malum prohibitum, and good faith cannot be used as a defense. It also upholds that an employee can be liable as principal in illegal recruitment if actively participating in recruitment activities. The case also stresses the binding nature of the findings of fact when affirmed by the Court of Appeals.
### Class Notes:
1. **Elements of Illegal Recruitment in Large Scale:**
– Undertaking recruitment activities as defined in Article 13(b) of the Labor Code.
– Lack of license or authority from POEA.
– Recruitment committed against three or more persons.
2. **Legal Citations:**
– **Article 13(b) of the Labor Code:** Definition of “recruitment and placement.”
– **Article 38(a) and (b) of the Labor Code:** Illegal recruitment by non-licensees and economic sabotage.
– **Article 39(a):** Penalty of life imprisonment and fine for economic sabotage.
### Historical Background:
This case falls into a broader context of fraudulent overseas employment schemes prevalent in the 1990s, which saw the exploitation of Filipino workers seeking better opportunities abroad. The regulatory framework of the POEA exists to combat such fraudulent practices, making this case a vital precedent in the enforcement of laws against illegal recruitment.
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