ROSA C. RODOLFO v. PEOPLE

FACTS:

The petitioner in this case was charged with illegal recruitment for recruiting and promising employment abroad without the required license or authority. The trial court found her guilty and sentenced her to eight years of imprisonment. On appeal, the Court of Appeals affirmed the judgment but modified the penalty. The appellate court found that the petitioner approached individual complainants and invited them to apply for overseas employment. The complainants gave money to the petitioner for processing and other fees, but their departure was repeatedly delayed, leading them to suspect deception. The prosecution presented a witness to establish that the petitioner had no authority for recruitment. However, the petitioner denied recruiting the complainants and instead asserted that they sought her assistance in securing overseas jobs. She claimed that she received money from them in trust for the agency. The appellate court dismissed the petitioner's appeal but modified the penalty. The petitioner's motion for reconsideration was denied, prompting her to file the present petition. She questioned the credibility of the witnesses and argued that the prosecution failed to prove her guilt beyond reasonable doubt. Additionally, she cited a previous Supreme Court case that held that the issuance or signing of receipts for placement fees does not necessarily constitute illegal recruitment.

ISSUES:

  1. Whether the testimonies of the complaining witnesses should be credited.

  2. Whether the prosecution proved the guilt of the petitioner beyond reasonable doubt.

RULING:

  1. The testimonies of the complaining witnesses were properly credited by the court. The court found that the testimonies of Necitas Ferre and Narciso Corpus, the private complainants, were consistent and corroborated by other evidence. The Court of Appeals correctly considered the evidence presented by the prosecution that showed the petitioner approached the private complainants and invited them to apply for overseas employment. The court also noted that the petitioner failed to refute the testimonies of the private complainants or present any evidence to support her claims.

  2. The prosecution proved the guilt of the petitioner beyond reasonable doubt. The court found that the evidence presented by the prosecution, including the testimonies of the private complainants and the witness from the Philippine Overseas Employment Agency (POEA), established that the petitioner did not have the required license or authority to recruit workers for overseas employment. The court also noted that the petitioner admitted to receiving money from the private complainants, but failed to return the money as promised. The court found that these acts constituted illegal recruitment.

PRINCIPLES:

  • Testimonies of witnesses may be credited if they are consistent, corroborated by other evidence, and remain unrebutted by the accused.

  • The prosecution has the burden of proving the guilt of the accused beyond reasonable doubt.