GR 112178 79; (April, 1995) (Digest)
G.R. Nos. 112178-79. April 21, 1995.
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. AIDA HONRADA, accused-appellant.
FACTS
Accused-appellant Aida Honrada was convicted by the Regional Trial Court of Cavite for Illegal Recruitment in Large Scale and four counts of Estafa. The prosecution established that from January to April 1991, Honrada, without the requisite license from the Department of Labor and Employment, recruited fourteen individuals for factory work in Japan, collecting fees totaling P132,830.00. She represented herself as a coordinator for the Low Income Filipino Entrepreneurs (LIFE) Foundation, promising to facilitate employment and process documents through the POEA and Japanese Embassy. Despite repeated promises and deadlines for departure, none of the complainants were deployed abroad.
For the estafa charges, the Information specified that Honrada, by means of deceit and false pretenses of having power to secure overseas employment, received specific sums from individual complainants (e.g., Rommel Garcia, P13,120.00) with the obligation to provide jobs. Upon receiving the money, she misappropriated the funds for her own use and failed to secure any employment, despite demands for reimbursement. The cases were jointly tried, with several victims testifying to giving payments and receiving unfulfilled promises.
ISSUE
The core issue is whether the prosecution proved beyond reasonable doubt the elements of Illegal Recruitment in Large Scale and Estafa against appellant Aida Honrada.
RULING
The Supreme Court affirmed the convictions. For Illegal Recruitment in Large Scale under Article 38(b) of the Labor Code, as amended, three elements must concur: (1) the accused undertook recruitment activities; (2) she did not have the required license or authority from the DOLE; and (3) she committed the same against three or more persons. The evidence conclusively showed Honrada engaged in recruitment by promising jobs, processing documents, and collecting fees. The POEA certification confirmed she was neither licensed nor authorized. Testimonies of multiple complainants satisfied the third element, making the crime one in large scale, which is economic sabotage punishable by life imprisonment.
For Estafa under Article 315(2)(a) of the Revised Penal Code, the elements of deceit, damage, and reliance were proven. Honrada’s false representations of being a coordinator with influence to secure jobs abroad induced the complainants to part with their money. This deceit was the direct cause of the financial damage they suffered when no employment materialized and their money was not refunded. The Court found her defense—that she was merely an agent collecting fees for the LIFE Foundation—untenable. The foundation’s alleged involvement did not absolve her, as she actively perpetrated the fraud by personally making representations, collecting cash, and issuing receipts, thereby clearly acting in conspiracy to defraud the victims.
