G.R. No. 225730 February 28, 2018
THE PEOPLE OF THE PHILIPPINES, Plaintiff-Appellee vs. JULIA REGALADO ESTRADA, Accused-Appellant

FACTS

Accused-appellant Julia Regalado Estrada was charged with Illegal Recruitment in Large Scale under R.A. No. 8042 and three counts of Estafa. The prosecution presented three private complainants: Noel Sevillena, Janice Antonio, and Albert Cortez. They testified that Estrada, representing herself as an employee of ABCA International Corporation, promised them employment in Dubai as a Master Baker, Service Crew, and Waiter, respectively. Relying on these representations, they gave her various amounts totaling over one hundred thousand pesos for processing fees and other expenses. Estrada failed to secure their employment or return their money. A certification from the Philippine Overseas Employment Administration (POEA) confirmed that Estrada was not licensed to recruit workers for overseas employment.
The defense presented Estrada and a representative from ABCA. Estrada claimed she was merely an administrative assistant who helped process documents for the complainants as a favor, denying she received money from Sevillena and Antonio, and asserting Cortez’s payment was for a legitimate placement fee to the agency. The ABCA representative testified Estrada was their Marketing Coordinator but was not authorized to collect fees. The Regional Trial Court found Estrada guilty on all counts, a decision affirmed by the Court of Appeals.

ISSUE

The core issue is whether the prosecution proved Estrada’s guilt for Illegal Recruitment in Large Scale and Estafa beyond reasonable doubt.

RULING

The Supreme Court affirmed the convictions. For Illegal Recruitment in Large Scale, the elements are: (1) the accused undertook recruitment activities; (2) she did not have the required license or authority from the POEA; and (3) she committed the same against three or more persons individually or as a group. All elements were established. Estrada’s acts of promising overseas jobs, requiring payment, and processing documents constitute recruitment under the law. The POEA certification conclusively proved her lack of license. The testimonies of three complainants satisfy the third element, making the crime large scale, which is economic in nature and punishable by life imprisonment.
For the three counts of Estafa under Article 315(2)(a) of the Revised Penal Code, the elements are: (1) the accused defrauded another by abuse of confidence or deceit; (2) damage or prejudice is caused to the offended party. Estrada’s false representations of her capacity to secure overseas employment clearly constituted deceit, which induced the complainants to part with their money. Their consequent financial loss and the failure to receive the promised employment established damage. The defense of mere denial cannot prevail over the complainants’ positive, categorical, and consistent testimonies. The Court found no reason to deviate from the factual findings of the trial court, which are accorded great weight and respect. The appealed decision was thus affirmed in toto.