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PEOPLE v. MANUEL DE GUIA Y SAMONTE

FACTS:

Manuel de Guia y Samonte, the accused-appellant, was convicted by the Regional Trial Court of Manila for illegally recruiting Filipino workers for employment abroad and committing three counts of estafa. The first information stated that the accused recruited and promised employment abroad to four individuals without the required license or authority from the Department of Labor and Employment. The second information alleged that the accused defrauded Leopoldo Realino by falsely representing that he had the authority to recruit and employ Realino as a factory worker in Japan, inducing Realino to give him P120,000, which the accused misappropriated. The third information stated that the accused defrauded Jesus Sumalinog by falsely representing that he had the authority to recruit and employ Sumalinog as a contract worker in Japan, inducing Sumalinog to give him P50,000, which the accused misappropriated. The fourth information alleged that the accused defrauded Montesa Gazmin by falsely representing that he had the power and capacity to recruit and employ Gazmin as a factory worker in Korea, inducing Gazmin to give him P30,000, which the accused misappropriated.

The private complainant Cirilo Lising testified that he was introduced to the accused and Loida de Guia by his brother-in-law. The couple claimed they could facilitate his employment in Korea and asked him to prepare an initial amount of P9,700. On August 12, 1991, he submitted his passport and biodata to the accused's office and gave the amount to Loida. Later, he found out that both accused were not licensed recruiters. Montessa Gasmin testified that she learned about the couple's job placement overseas from her cousin. She applied for a factory worker position in Korea and gave P30,000 to Loida in two installments. She was assured that she could leave for Korea, but the promise turned out to be false. Leopoldo Realino testified that he inquired about employment in Japan from the accused and later applied as a contract worker, paying P120,000. However, despite repeated promises, he was not employed and demanded the return of his money. Subsequently, the private complainants reported the matter to the authorities.

ISSUES:

  1. Whether the accused is guilty beyond reasonable doubt of illegal recruitment committed in large scale.

  2. Whether the accused is guilty beyond reasonable doubt of estafa in relation to the complainant Leopoldo Realino.

  3. Whether the accused is guilty beyond reasonable doubt of estafa in relation to the complainant Jesus Sumalinog.

  4. Did the trial court err in failing to prosecute Loida de Guia as one of the accused?

  5. Did the trial court err in convicting the accused based on hearsay evidence?

  6. Whether or not the testimony of the defense witness, Samonte, was credible and sufficient to cast doubt on the guilt of the appellant.

  7. Whether or not the warrantless arrest of the appellant would render his conviction void.

RULING:

  1. The accused is found guilty beyond reasonable doubt of illegal recruitment committed in large scale and is sentenced to life imprisonment and ordered to pay a fine of P100,000. The accused is also ordered to pay the complainant Cirilo Lising the sum of P9,700 as actual damages.

  2. The accused is found guilty beyond reasonable doubt of estafa in relation to the complainant Leopoldo Realino. The accused is sentenced to an indeterminate sentence ranging from eight years and one day of prision mayor as minimum to fourteen years, five months, and eleven days of reclusion temporal as maximum. The accused is also ordered to indemnify the complainant Leopoldo Realino the sum of P120,000 as actual damages.

  3. The accused is found guilty beyond reasonable doubt of estafa in relation to the complainant Jesus Sumalinog. The accused is sentenced to an indeterminate sentence ranging from three years, six months, and twenty-one days of prision correccional as minimum to seven years, five months, and eleven days of prision mayor as maximum. The accused is also ordered to indemnify the complainant Jesus Sumalinog the sum of P50,000 as actual damages.

  4. The court found that the accused cannot fault the decision of the trial court even if the real perpetrator, Loida de Guia, was not prosecuted. The Informations against the accused specifically charged him with conspiring and confederating with an unknown person, whose true name and whereabouts are still unknown. The state can still charge Loida de Guia once her true identity and address become known, but her non-prosecution at this stage does not provide grounds for the appellant to question his conviction.

  5. The court concluded that the receipts issued by Loida de Guia were not hearsay evidence. The complainants testified that they personally handed the money to the accused, who then instructed Loida to prepare the receipts. The receipts were signed by Loida in the presence of the complaining witnesses. Therefore, the complaining witnesses had personal knowledge of the circumstances surrounding the issuance of the receipts, and their testimonies cannot be considered hearsay evidence.

  6. The testimony of the defense witness was deemed unimpressive and lacked corroboration. Therefore, it did not sufficiently cast doubt on the appellant's guilt. The defense witness's testimony, unsupported by documentary evidence, has little value. The court also considered that even if the appellant was a part-time driver, it would not make it physically impossible for him to operate a recruitment business.

  7. The appellant's alleged warrantless arrest would not exculpate him from his guilt. The court noted that the appellant pleaded not guilty to the charges upon arraignment, and there was no prior assertion of the alleged illegality of his arrest. The court ruled that the appellant's plea waived the alleged illegality of his arrest, and it cannot render all other proceedings, including his conviction, void.

PRINCIPLES:

  • Illegal recruitment committed in large scale is a crime punishable under the law.

  • Estafa is a crime that involves the deprivation of property or the use of deceit or fraudulent means.

  • Indeterminate sentence allows for a minimum and maximum penalty, giving the court flexibility in determining the appropriate punishment based on the circumstances of the case.

  • Alibi, as a weak defense, must be proved by clear and convincing evidence.

  • Testimony lacking corroboration and documentary evidence may have little value.

  • The alleged illegality of an arrest does not deprive the state its right to convict the guilty when all the facts on record point to the accused's culpability.