Short answer. Yes. The Labor Code's definition of recruitment and placement expressly includes referrals, and it applies whether the act is done for profit or not. Charging nothing keeps you outside the two-or-more-persons-for-a-fee clause, but it does not put the act itself outside the definition.
What the law says
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
Labor Code, Article 13 — Key Recruitment Terms Defined. Read the full provision →
What the law says
any person or association engaged in the recruitment and placement of workers, locally or overseas, without charging, directly or indirectly, any fee from the workers or employers
Labor Code, Article 13 — Key Recruitment Terms Defined. Read the full provision →
Referrals are named in the definition
Recruitment and placement is defined 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. Referrals appear on the face of it, and so does the answer to the fee question: whether for profit or not. The definition was drafted to describe activity, not commerce. Whether money changed hands goes to which category of operator you are and what document you needed — not to whether what you did was recruitment at all.
The clause people confuse this with
Article 13 contains a separate sentence deeming anyone who offers or promises employment for a fee to two or more persons to be engaged in recruitment and placement. That clause is a shortcut for proving the point in fee-charging cases, and it is the one most people have half-remembered when they say that recruitment requires a fee and two victims. It adds a route into the definition. It does not narrow the definition it sits inside, which already reaches referrals made for nothing.
The Code has a category for unpaid recruiters
This is the part that surprises people. The Code defines a private recruitment entity as any person or association engaged in the recruitment and placement of workers, locally or overseas, without charging, directly or indirectly, any fee from the workers or employers, and it defines an authority as the document from the Department of Labor permitting exactly that. In other words the Code anticipated the fee-free recruiter and required a document from him too. Not charging does not lift you out of the scheme; it moves you from the licence column into the authority column.
Where an honest favour ends
None of this makes it unlawful to tell a friend that your employer is hiring, or to pass a name to your own HR department. What changes the character of the act is doing it as an activity: approaching people you do not know, holding yourself out as able to place them, handling their papers, collecting anything from them, or standing between them and an employer abroad. If you find yourself doing several of those for strangers, you are no longer doing a favour, and the question of whether you hold a licence or an authority has become a live one.