AURO, IAN DEO A.

LABOR LAW 1 BLOCK A

PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee,

vs.
EDITH RAMOS ABAT, Accused-Appellant.
G.R. No. 168651

March 16, 2011

FACTS:
Edith Ramos Abat (Abat), without a license to recruit from the DOLE, recruited several
persons and promised them employment in Taiwan. In consideration to said promise she
tendered payments from them but failed to deploy them. She was convicted by the trial court for
illegal recruitment in large scale sentencing her to lifetime imprisonment. Abat refutes that the
amounts she received from them were mere reimbursement for an all- expense paid trip with the
complainants shouldered by her. She also avers that the failure of the prosecution to present
receipts evidencing that the payments were made in consideration of their recruitment and the
non-presentment of 5 out of 9 complainants as witnesses weakens the case against her and
warrants her release on the ground of reasonable doubt. The Court of Appeals, however,
sustained the decision of the trial court. Hence, this appeal.
ISSUES:
Does the non-presentment of majority of the complainants as witnesses weakens the stand
of the state against an illegal recruitment case?
Does the failure of the prosecution to present receipts evidencing that the payments made
by the complainants to the accused were in consideration of their employment abroad,
negate the guilt of the accused.
RULING:
The Court ruled that there were sufficient evidence to prove her guilt on the crime
charged. The certification from the DOLE and her admission that she was not a licensed recruiter
satisfies one of the essential elements of illegal recruitment. Her denial that the payments she
received from the complainants were mere reimbursement for the expenses she paid for the
outings cannot prevail over the combined testimonies of the witnesses that they were led to
believe that the payments they have made were in consideration of their application to work in
Taiwan and not for the trips. The presentment of only 4 out of 9 witnesses does not in any way
weaken the stand of the state against her because it has long been ruled that in court
adjudications, the courts do not count but weigh witnesses; thus, quality of witness, not their
quantity, is considered. Finally, the failure of the State to present receipts proving that the
payments by the complainants was in consideration of their recruitment to Taiwan does not
negate the guilt of the accused. The absence of receipts in a criminal case for illegal recruitment
does not warrant the acquittal of the accused and is not fatal to the case of the prosecution. As
long as the witnesses had positively shown through their respective testimonies that the accused
is the one involved in the prohibited recruitment, he may be convicted of the offense despite the
want of receipts. Therefore, the Court rules that the findings of the lower courts were correct and
the penalties imposed were proper. In view thereof, the assailed decision of the Court of appeals
was affirmed.