A Certification61 dated February 3, 1995, issued by the same agency, also states that: "MRS. FLOR T. GUTIERREZ was (sic) employed as OVERSEAS MARKETING DIRECTRESS of SARIFUDIN MANPOWER AND GENERAL SERVICES, effective May 1994, up to the present" 62 The defense also submitted several documents to prove compliance with the requirements of the agency for her to assume her duties under the SPA. These include receipts63 for a cash bond in the amount of P30,000.00 that she paid in several installments. She also paid a royalty fee of P4,000.0064 and an office rental fee of P3,000.00.65 The accused was also required by the agency to submit a monthly report for June 1994, as evidenced by a Memorandum signed by the General Manager, Leah Salud.66 She submitted said monthly report, indeed, several monthly reports. 67 A document calling on all Marketing Directresses/Directors to attend a meeting on July 8, 1994, was also presented.68 The accused did not receive any salary or allowances from Sarifudin but received commissions from the agency's principals, the employers from foreign countries (ten in the Middle East and two in Singapore) at the rate of U.S. $100.00 per person.69 From her commissions, she paid rent and royalty to Sarifudin.70 Edwin Cristobal, POEA Labor Employment Officer, confirmed that Sarifudin was duly licensed to engage in recruitment activities.71 He presented a Certification issued by Ma. Salome S. Mendoza, Manager of the Licensing Branch72 and containing the list of officers and staff of Sarifudin. On said list appear the names "Florna Gutierrez" and "Flor Gutierrez,"73 apparently, one and the same person.74 In the same Certification, appears the following: It is further certified that the said agency revoked the appointment of Ms. Flor Gutierrez as Overseas Mktg. Director/Manager in a letter dated Dec. 15, 1995, although this Office has not received nor acknowledged the representation of Ms. Gutierrez.75 Cristobal explained that the POEA, "Never had a letter from Sarifudin registering or authorizing Flor Gutierrez... rather, [what] we received [was a] revocation of her appointment."76 He also revealed that the name of the accused does not appear in the records of the POEA as being employed by the agency from the assumption of its license on June 11, 1993, up to its termination on June 11, 1995. 77 The defense likewise alleged that complainants Rosemarie Tugade and Evelyn Ramos executed Affidavits of Desistance dated May 12, 1995,78 stating that the accused had returned to them the amounts they paid her and that the complaint was a result of a misunderstanding. On March 22, 1996, the trial court rendered its Decision finding the accused guilty beyond reasonable doubt of Illegal Recruitment in Large Scale: WHEREFORE, after evaluating all the foregoing, the accused FLOR GUTIERREZ is hereby found guilty beyond reasonable doubt of Illegal Recruitment in Large Scale, and judgment is hereby rendered as follows: (a) Convicting the accused of Illegal Recruitment in Large Scale and sentencing her to suffer the penalty of life imprisonment and payment of P100,000.00 fine; (b) No reimbursement to complainants is needed since their money have already been returned; (c) Accused to pay moral damages in the amount of P50,000.00 to each complainant; (d) Accused to pay exemplary damages in the amount of P50,000.00 to each complainant; and (e) To pay the costs of the suit.79 Accused Flor Gutierrez filed the present appeal seeking the reversal of her conviction. Illegal recruitment is committed when two elements concur, namely: (1) the offender has no valid license or authority required by law to enable one to lawfully engage in recruitment and placement of workers; and (2) he undertakes either any activity within the meaning of "recruitment and placement" defined under Art. 13(b), or any of the prohibited practices enumerated under Art. 34 of the Labor Code. 80 Art. 13(b) of the Labor Code defines "recruitment and placement" as "any act of canvassing, enlisting, contracting, transporting, utilizing, hiring, or procuring workers, and includes referrals, contract services, promising or advertising for employment, locally or abroad, whether for profit or not: Provided, That any person or entity which, in any manner, offers or promises for a fee employment to two or more persons, shall be deemed engaged in recruitment and placement."81 The crime becomes Illegal Recruitment in Large Scale when the two elements concur, with the addition of a third element: the recruiter committed the same against three or more persons, individually or as a group. 82 Appellant argues that as a representative of a duly licensed recruitment agency, she cannot be held guilty of Illegal Recruitment in Large Scale. We disagree. Section 11, Rule II, Book II of the Rules and Regulations Governing Overseas Employment requires the prior approval of the POEA of the appointment of representatives or agents: Section 11. Appointment of Representatives. Every appointment of representatives or agents of licensed agency shall be subject to prior approval or authority of the Administration.