G.R. No. 97849 -54 March 1, 1994
People of the Philippines, plaintiff-appellee, vs. Elizabeth Coral y Adelan, accused-appellant.

FACTS

Accused-appellant Elizabeth Coral was charged with Illegal Recruitment in Large Scale (Criminal Case No. 90-82870) and five counts of Estafa (Criminal Cases No. 90-82871 to 90-82875). The Information for Illegal Recruitment alleged that on or about December 27, 1989, in Manila, she willfully and unlawfully, for a fee, recruited and promised employment abroad to Bella Bustria, Glenda Elefante, Jossie Cayaga, Remedios Casiano, and Milliarrina Romaldo without the necessary license or authority from the Department of Labor. The Informations for Estafa similarly alleged that on or about the same date, she defrauded each complainant by falsely representing she had the capacity to recruit and employ them abroad, thereby inducing them to deliver various amounts (e.g., P25,000.00 from Bella Bustria) which she misappropriated.
At trial, the prosecution presented four private complainants: Glenda Elefante, Bella Bustria, Jossie Cayaga, and Remedios Casiano. Their collective testimonies established that they were introduced to accused-appellant by Nora Rubias. Accused-appellant operated from an office at 1010 A. Mabini St., Ermita, Manila, where she promised them jobs as factory workers in Taiwan or South Korea in exchange for payments for visa processing, passports, and placement fees ranging from P1,500.00 to P25,000.00. Payments were made on various dates, including August 27 and December 27, 1989, and January 15, 1990. A single receipt for P60,000.00 was issued on December 27, 1989, covering payments from Glenda, Bella, and Jossie, signed by accused-appellant’s secretary, Jimmy Magno. Accused-appellant repeatedly failed to deploy the complainants, giving excuses such as embassy strictness and the Chinese New Year. Complainant Remedios Casiano, who had returned from Korea, warned the others about fake visas and mistreatment. The complainants verified with the Philippine Overseas Employment Administration (POEA) that accused-appellant was not a licensed recruiter and subsequently filed complaints with the police.
The defense presented accused-appellant, who denied the charges, claiming the cases were fabricated because the complainants owed her money from a previous jewelry business. She alleged that the receipt for P60,000.00 was for a jewelry transaction, not recruitment fees. She also claimed she was a journalism graduate and a third-year law student. The trial court, after the parties agreed to submit the evidence adduced during the hearing on the Petition for Bail as the evidence on the merits, convicted accused-appellant.

ISSUE

The primary issue is whether the trial court erred in convicting accused-appellant of Illegal Recruitment in Large Scale and multiple counts of Estafa based on the evidence presented.

RULING

The Supreme Court AFFIRMED the trial court’s decision in toto. The Court held that the prosecution successfully proved all elements of Illegal Recruitment in Large Scale: (1) accused-appellant undertook recruitment activities without the required license or authority from the POEA, and (2) she committed the same against five persons. The testimonies of the four complainants were found credible, consistent, and sufficient to establish her guilt beyond reasonable doubt. Their positive identification of accused-appellant, coupled with the POEA certification confirming her lack of license, constituted strong evidence.
The Court also found accused-appellant guilty of four counts of Estafa under Article 315(2)(a) of the Revised Penal Code. The elements of deceit and damage were proven through the complainants’ testimonies detailing how accused-appellant’s false representations about her capacity to secure overseas employment induced them to part with their money, which she then misappropriated.
The Court rejected accused-appellant’s defenses. Her claim that the cases were fabricated due to a jewelry debt was unsupported by evidence and belied by the clear and convincing testimonies of the complainants. Her argument that she was denied due process because she was not informed that the bail hearing evidence would be used for the merits was also dismissed. The Court noted that an Order dated December 18, 1990, stated the parties’ agreement to submit the bail hearing evidence as the evidence on the merits, and accused-appellant, a journalism graduate and law student, did not contest this Order nor indicate what additional evidence she would have presented.
Thus, the conviction for Illegal Recruitment in Large Scale (carrying a life sentence) and four counts of Estafa was upheld.