Marajas v. People
REITERATIONFacts
The Antecedents: Petitioner Aquilina M. Marajas and co-accused Myrna Melgarejo were charged with violation of Section 6 of Republic Act (R.A.) No. 8042 (Illegal Recruitment) and Section 5(e) of R.A. No. 9208 (Anti-Trafficking in Persons Act of 2003). The charges stemmed from an incident on May 31, 2012, where Nieves Tag-at was referred for employment in Beijing, China, and facilitated her departure using falsified travel documents. Procedural History: The Regional Trial Court (RTC) of Pasay City, Branch 111, found petitioner guilty beyond reasonable doubt of illegal recruitment and violation of R.A. No. 9208. The Court of Appeals (CA) affirmed the conviction with modification, increasing the penalty for illegal recruitment and affirming the penalty for trafficking. The CA found the evidence sufficient to prove all elements of both offenses. Petitioner's motion for reconsideration was denied. The Petition: Petitioner filed a Petition for Review on Certiorari under Rule 45, assailing the CA's decision and resolution. She argued that the prosecution failed to prove her guilt beyond reasonable doubt, specifically questioning the first element of illegal recruitment (undertaking recruitment or placement activities) and asserting that her actions did not constitute trafficking as she did not assist in the departure or provide fraudulent documents.
Issue(s)
Whether the CA gravely erred in finding petitioner guilty of Illegal Recruitment under Section 6 of R.A. No. 8042. Whether the CA gravely erred in finding petitioner guilty of Trafficking in Persons under Section 5(e) of R.A. No. 9208.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals, upholding the conviction of Aquilina M. Marajas for Illegal Recruitment under Section 6 of R.A. No. 8042, as amended by R.A. No. 10022, and for Trafficking in Persons under Section 5(e) of R.A. No. 9208. The Court found no reversible error in the CA's findings.
Ratio Decidendi
On the issue of Illegal Recruitment: The Court affirmed the CA's finding that petitioner was guilty of illegal recruitment. The second element, lack of license or authority, was proven by a POEA Certification, which petitioner did not deny. Regarding the first element, while the private complainant testified that petitioner did not explicitly promise employment, petitioner's actions, such as telling the private complainant there would be work upon arrival in Beijing, giving her a fraudulent Letter of Invitation and Support, and accompanying her to the airport, created the distinct impression that she had the power to send workers abroad. The Court reiterated that denial is a weak defense against positive and credible testimony, especially when the testimony is corroborated by other evidence and the witness has no ill motive. On the issue of Trafficking in Persons: The Court sustained the CA's ruling that petitioner was guilty of violating Section 5(e) of R.A. No. 9208. The prosecution successfully established the elements of the crime through the consistent and credible testimony of the private complainant and other witnesses. Petitioner facilitated and assisted the private complainant's departure using fraudulent travel documents, with the purpose of employment in Beijing, China. This was corroborated by NBI agents who overheard petitioner's instructions and by the Immigration Officer who found the documents to be spurious. The Court found no ill motive on the part of the prosecution witnesses to cast doubt on their testimonies.
Main Doctrine
A person is liable for illegal recruitment if they undertake recruitment and placement activities without a license or authority, giving the impression of having the power to send workers abroad. Facilitating a person's departure from the country using fraudulent travel documents for employment purposes constitutes trafficking in persons.