Short answer. Very likely yes. Article 38 provides that any recruitment activities undertaken by non-licensees or non-holders of authority are deemed illegal. The absence of a licence is the point: what would be ordinary recruitment work in licensed hands becomes an offence when done by someone who holds no licence at all.
What the law says
Any recruitment activities, including the prohibited practices enumerated under Article 34 of this Code, to be undertaken by non-licensees or non-holders of authority, shall be deemed illegal
Labor Code, Article 38 — Illegal Recruitment Defined. Read the full provision →
It is the licence, not the lie, that decides it
People who have been recruited by an unlicensed person usually describe the deception first — the job that did not exist, the promises made. That matters, but it is not what the first sentence turns on. The clause covers any recruitment activities done by a non-licensee, and adds the prohibited practices on top rather than requiring them. So a recruiter with no licence is caught even where the job was real and the recruiter meant well. Whether he had authority is a fact you can check; whether he intended to cheat you is not.
Recruitment activity is broader than you expect
Someone need not run an office to be recruiting. Canvassing, enlisting, promising employment, collecting documents or fees, arranging interviews, and referring applicants to an employer for a share of the fee are all recruitment work. This is what catches the informal figure who says he is only helping — the neighbour with a contact abroad, the trainer who also "endorses" graduates. If he was gathering applicants for a job and money moved, describing himself as a facilitator does not change what he was doing.
Check the licence, and record that you checked
The single most useful fact in this kind of case is the recruiter's status on the date you dealt with him. Verify it against the official list of licensed agencies rather than against a certificate he shows you, and keep a dated screenshot of what you found. If he claimed to be acting for a licensed agency, that claim is worth pinning down in writing too, because a licensed agency is answerable for the people it actually designated and will say quickly if he was not one of them.
Do not wait to be the only complainant
Recruiters who operate without a licence rarely do it once, and the number of people affected changes the character of the case under this same article. Others who paid the same person are worth finding, and their receipts and messages corroborate yours. Meanwhile keep everything: proof of payment, the advertisement or message that reached you, the names and dates, and any document he issued. A complaint under this article may be initiated by the Department of Labor and Employment or by a law enforcement officer as well as by you.