G.R. No.

180926

PEOPLE OF THE PHILIPPINES, plaintiff-appellee,

vs.
LOURDES VALENCIANO y DACUBA, accused-appellant.

FACTS

 Valenciano, claiming to be an employee of Middle East International Manpower Resources, Inc.

recruited private complainants for overseas employment.
 She received the payments made by the complainants of their placement fees to the alleged
owners of the recruitment agency.
 Due to the failure of private complainants to be deployed, they filed a case for large scale illegal
recruitment against the appellant and the Imperials.
 The Imperials remained at large. The RTC found appellant guilty beyond reasonable doubt of the
crime imputed. On appeal, the Court of Appeals affirmed the trial court’s findings.

ISSUE

Whether or not appellant guilty of the crime of large scale illegal recruitment despite the claim that she
is just a mere employee of the recruitment agency?

HELD

The claim of accused-appellant that she was a mere employee of her other co-accused does not relieve
her of liability. An employee of a company or corporation engaged in illegal recruitment may be held liable
as principal, together with his employer, if it is shown that the employee actively and consciously
participated in illegal recruitment. The accused appellant must he held accountable for her acts. The Court
did not err in convicting her of Illegal Recruitment. Appellant cannot escape liability by claiming that she
was not aware that before working for her employer in the recruitment agency, she should first be
registered with the POEA. It is a legal maxim that “Ignorance of the law excuses no one. “Furthermore,
illegal recruitment in large scale is malum prohibitum, not malum in se, thus, intent is immaterial. It is also
a well settled rule that it is immaterial whether the accused profit or not from the illegal acts. Likewise, to
allow the accused to use a defense of good faith would be a circumvention of the law. Good faith cannot
be used as a defense since it will only warrant the illegal recruiters to use it as cloak of their illegal acts.