GR 235010; (August, 2024) (Digest)
G.R. No. 235010, August 07, 2024
People of the Philippines, Plaintiff-Appellee, vs. Sonia Valle y Lapurga, Accused-Appellant.
FACTS
Accused-appellant Sonia Valle y Lapurga was charged with two counts of illegal recruitment in large scale and nine counts of estafa. This appeal concerns one count of illegal recruitment in large scale (Criminal Case No. 12468) and four counts of estafa (Criminal Cases Nos. 12469, 12472, 12473, and 12474). The Informations alleged that in October 2001, in Cabanatuan City, accused-appellant, without being a licensed recruiter, undertook recruitment activities by promising jobs in Guam to six individuals (Marcos Untalan, Crisanto Cando, Ronel Relucio, Gerardo Cando, Jr., Dionisio Salazar, and Mario Calpito) and collected a total of PHP 460,500.00 from them. The separate estafa charges involved specific amounts obtained from Calpito (PHP 44,000), Cando (PHP 78,500), Salazar (PHP 30,000), and Untalan (PHP 157,000) through false pretenses of being a legitimate recruiter. Accused-appellant pleaded not guilty. The prosecution presented the private complainants as witnesses, who testified that they paid various sums to accused-appellant based on her representations that she could secure jobs for them in Guam through a sister working at a recruitment agency. No receipts were issued. The promised deployment did not materialize, and accused-appellant failed to return the money. The defense presented accused-appellant and her daughter, who claimed the money was a loan for a business venture. The Regional Trial Court convicted accused-appellant of one count of illegal recruitment in large scale and four counts of estafa. The Court of Appeals affirmed the RTC’s decision. Accused-appellant appealed to the Supreme Court.
ISSUE
The core issue is whether the Court of Appeals erred in affirming accused-appellant’s conviction for Illegal Recruitment in Large Scale and four counts of Estafa.
RULING
The Supreme Court DENIED the appeal and AFFIRMED the Court of Appeals Decision with MODIFICATIONS regarding the penalties and interest. The Court found the elements of Illegal Recruitment in Large Scale and Estafa were proven beyond reasonable doubt.
1. On Illegal Recruitment in Large Scale: The Court held all three elements were present: (a) accused-appellant undertook recruitment activities by promising overseas employment in Guam; (b) she had no valid license or authority from the POEA, as certified by a POEA representative; and (c) she committed the acts against three or more persons (Untalan, Cando, Salazar, and Calpito). Her defense that the money was a loan was rejected for being self-serving and uncorroborated, and it did not negate the clear evidence of recruitment.
2. On Estafa under Article 315(2)(a) of the RPC: The Court found the elements were established for the four counts: (a) accused-appellant made false pretenses of being a licensed recruiter capable of securing jobs in Guam; (b) such pretenses were made prior to or simultaneous with the receipt of money; (c) the complainants were induced to deliver the money due to these pretenses; and (d) the complainants suffered damage. The defense of loan was again rejected.
3. On Penalties:
* For Illegal Recruitment in Large Scale, the Court imposed life imprisonment and a fine of PHP 2,000,000.00, pursuant to Republic Act No. 8042.
* For Estafa, applying Republic Act No. 10951, the penalties were based on the amounts defrauded. The Court imposed indeterminate prison sentences for each count: 4 months and 20 days of arresto mayor as minimum to 2 years and 4 months of prision correccional as maximum for defrauding Calpito (PHP 44,000); 6 months of arresto mayor as minimum to 4 years and 2 months of prision correccional as maximum for defrauding Cando (PHP 78,500); 4 months of arresto mayor as minimum to 2 years and 4 months of prision correccional as maximum for defrauding Salazar (PHP 30,000); and 1 year and 8 months of prision correccional as minimum to 8 years of prision correccional as maximum for defrauding Untalan (PHP 157,000).
4. On Civil Liability: Accused-appellant was ordered to pay each complainant the specific amounts defrauded, with legal interest at 6% per annum from the date of finality of the judgment until full payment.