People v. Sendon
REITERATIONFacts
The Antecedents: Three separate Informations were filed charging Lucille B. Sendon with Illegal Recruitment under Article 38 of P.D. 442 (Labor Code), as amended by P.D. 1693, P.D. 1920, and P.D. 2018, and penalized under Article 39. In Criminal Case No. IR-2577, Bernie de Villa was defrauded of P15,000.00; in Criminal Case No. IR-2582, Arnel V. Ibias was defrauded of P16,500.00; and in Criminal Case No. IR-2592, Gerardo P. Escano was defrauded of P7,000.00. All were promised employment in the Sultanate of Oman with specified salaries and assistance for travel papers, which promises were not realized. The illegal recruitment was alleged to be in large scale, involving economic sabotage. The accused pleaded not guilty to the charges. The cases were consolidated and jointly tried. Procedural History: The Regional Trial Court, Fifth Judicial Region, Branch 35 of Iligan City, in its decision dated August 8, 1990, found the accused Lucille B. Sendon guilty beyond reasonable doubt of Illegal Recruitment and sentenced her to pay a fine of P20,000.00 in each case, with subsidiary imprisonment in case of non-payment, and to return the amounts defrauded to each complainant. Subsequently, on September 19, 1990, the trial court amended its decision based on a motion for reconsideration, finding the accused guilty of Illegal Recruitment in Large Scale and sentencing her to suffer life imprisonment and a fine of P100,000.00, and to return the amounts defrauded. The Petition: The accused-appellant appealed the decision, raising two assignments of error: (I) the trial court erred in giving weight and credence to the contradictory testimonies of the three complaining witnesses, and (II) the trial court erred in not acquitting the accused-appellant on the ground of reasonable doubt.
Issue(s)
Whether the trial court erred in giving weight and credence to the testimonies of the complaining witnesses. Whether the accused-appellant should be acquitted on the ground of reasonable doubt.
Ruling
The appealed decision is hereby AFFIRMED. The accused-appellant is found GUILTY BEYOND REASONABLE DOUBT OF ILLEGAL RECRUITMENT IN LARGE SCALE as defined in Section 38 of the Labor Code, as amended by Presidential Decrees Numbers 1920 and 2018.
Ratio Decidendi
On the credibility of witnesses: The Supreme Court affirmed the trial court's findings, holding that when the issue involves the credibility of witnesses, the trial court's conclusions are entitled to great weight and respect on appeal. The Court found that the alleged inconsistencies in the testimonies of the prosecution witnesses pertained only to minor details and collateral matters, which do not affect the substance of their declarations, their veracity, or the weight of their testimony. In fact, such minor discrepancies are expected from uncoached witnesses and can even reinforce their credibility. On reasonable doubt and guilt beyond reasonable doubt: The Court emphasized that the place where the money was given is not material; what is important is that the accused-appellant lured the complainants and received money from them. The fact of payment was duly established, and admitted by the appellant when she executed a promissory note. The appellant's claim that she signed the promissory note believing her co-accused would return the money was not given credit, as she failed to present evidence that it was her co-accused who enticed the complainants, suggesting the co-accused was a phoney participant. The Court concluded that the appellant's guilt has been proved beyond reasonable doubt, as it was established that she, without a license to recruit overseas workers, convinced the complainants to work abroad, received money from them, and failed to provide the promised jobs or return the money.
Main Doctrine
The accused is guilty beyond reasonable doubt of Illegal Recruitment in Large Scale as defined in Section 38 of the Labor Code, as amended by Presidential Decrees Numbers 1920 and 2018, for luring complainants to work abroad, receiving money from them for plane tickets and other expenses, and failing to provide the promised employment or return the money.