People v. Laogo

G.R. No. 176264 (January 10, 2011)

Facts:

Appellant Teresita "Tessie" Laogo was the proprietor and manager of Laogo Travel Consultancy, a travel agency located in Manila. On March 7, 2001, an Information was filed against her and a certain Susan Navarro, charging them with illegal recruitment in large scale under the Labor Code of the Philippines. The charge stemmed from events that occurred during May and June 2000, where the accused, knowing they were not licensed to recruit workers, engaged in illegal recruitment activities by promising job placements abroad, specifically in Guam, to several complainants in exchange for fees.

The complainants, including Teodulo dela Cruz, Billy dela Cruz Jr., Dante Lopez, Rogelio Enriquez, Edwin Enriquez, and Gary Bustillos, were introduced to Susan by Gary Bustillos during a town fiesta. They were led to believe that Susan could help them secure employment abroad. Each complainant paid various amounts to Susan, who then took them to Laogo Travel Consultancy, where they paid additional fees to appellant Laogo. Receipts were issued for these payments, which bore the name and logo of Laogo Travel Consultancy and were signed by Susan or appellant.

As months passed without any job placements materializing, the complainants became suspicious and eventually reported the matter to the authorities, leading to the filing of the complaint against both accused. Appellant Laogo denied any involvement in the illegal activities, claiming that she was unaware of Susan's actions and that her agency was only involved in assisting clients with passport and visa procurement.

The Regional Trial Court (RTC) found Laogo guilty of illegal recruitment in large scale, sentencing her to life imprisonment and imposing a fine, along with ordering her to indemnify the complainants for their losses. Laogo appealed the decision, which was subsequently affirmed by the Court of Appeals (CA).

Legal Issues:

1. Whether Teresita Laogo was guilty of illegal recruitment in large scale despite her claims of non-involvement.
2. Whether the actions of Laogo and Susan constituted illegal recruitment as defined under the Labor Code.

Arguments:

Appellant's Arguments:

• Laogo contended that she had no direct involvement in the recruitment activities and that all transactions were conducted through Susan Navarro.
• She argued that her travel agency was not engaged in recruitment activities as defined by law and that she was merely assisting clients with visa and passport applications.
• Laogo claimed that her decision to change the name of her travel agency was a legitimate business move to dissociate from Susan's actions.

Appellee's Arguments:

• The prosecution maintained that both Laogo and Susan actively participated in the recruitment of the complainants, as evidenced by the payments made to them and the promises of employment.
• The prosecution argued that the issuance of receipts bearing the agency's name and Laogo's signature indicated her involvement in the illegal recruitment scheme.
• It was asserted that the actions of Laogo and Susan misled the complainants into believing they were dealing with a legitimate recruitment agency.

Court's Decision and Legal Reasoning:

The Supreme Court affirmed the decision of the Court of Appeals, which upheld the RTC's ruling. The Court reasoned that illegal recruitment is defined as the act of canvassing, enlisting, contracting, transporting, utilizing, hiring, or procuring workers, and includes any promise or offer of employment for a fee. The Court noted that both the trial court and the CA found sufficient evidence that Laogo, along with Susan, assured the complainants of their ability to send them abroad for work, which constituted illegal recruitment.

The Court emphasized that the complainants were led to believe that they were transacting with a legitimate recruitment agency, which was not licensed to operate as such. The issuance of receipts and the direct involvement of Laogo in the recruitment process were critical factors in establishing her guilt. The Court dismissed Laogo's claims of non-involvement and her attempt to distance herself from Susan's actions as insufficient to absolve her of liability.

Significant Legal Principles Established:

1. Definition of Illegal Recruitment: The Court reiterated that illegal recruitment encompasses a wide range of activities related to the recruitment and placement of workers, and that engaging in such activities without the necessary license constitutes a serious offense.
2. Joint Liability in Recruitment Schemes: The ruling underscored that individuals can be held jointly liable for illegal recruitment if they conspire or act in concert to mislead victims into parting with their money under false pretenses of employment.
3. Economic Sabotage: The Court recognized that illegal recruitment committed against three or more persons is considered large scale and is treated as economic sabotage, warranting harsher penalties.