People v. Laogo (G.R. No. 176264; January 10, 2011)

CASE DIGEST: PEOPLE OF THE PHILIPPINES vs. TERESITA "TESSIE" LAOGO. People v. Laogo (G.R. No. 176264; January 10, 2011).

FACTS: Appellant, along with a certain Susan Navarro, were found guilty of illegal recruitment. It was found that Navarro met the complainants in a town fiesta. Navarro invited the complainants into her house where she introduced them to appellant. Each of the complainants were told that Navarro would be able to help them secure employment abroad. The complainants then paid differing amounts to Navarro as placement fees, and were issued receipts bearing the logo of Laogo Travel Consultancy, the company of appellant. Complainants eventually found out that appellant and Navarro were not registered with the DOLE as a recruitment agency. Appellant was found guilty by the RTC, and her conviction was affirmed by the Court of Appeals. Appellant now challenges her conviction, contending that she was not affiliated with Navarro, and that her business involves the processing of visas. She was doing the same for the complainants, and was not, in any way, affiliated with Navarro.

ISSUE: Is appellant guilty of illegal recruitment?

HELD: The lower and appellate courts found that the transaction entered into by the complainants an appellant were followed up through appellant office. Also, the receipts issued to the complainants were from appellant company. The fact that she eventually changed the company name in an attempt to dissociate herself from Navarro deserves scant consideration. Appellant engaged in recruitment activities when she promised complainants employment abroad in exchange for consideration. She is guilty of illegal recruitment as she was unlicensed to undertake said act.