FACTS:

This case involves the appeal of accused-appellant Mary Lou Omictin from the decision of the Court of Appeals affirming the Regional Trial Court's (RTC) verdict. Omictin was found guilty of illegal recruitment in large scale and estafa. The private complainants, Primo Arvin Guevarra, Veronica Caponpon, Roy Fernandez Mago, and Anthony Ambrosio, sought overseas employment through Omictin and paid varying amounts as placement fees. However, Omictin failed to fulfill her promises and the complainants were unable to secure employment. Consequently, the private complainants filed complaints, leading to an entrapment operation wherein Omictin was arrested after receiving marked money. She was then charged separately for illegal recruitment and estafa. During the trial, Omictin denied any fraudulent intent, asserting that she was merely assisting the complainants in processing their visas. Nevertheless, the RTC found her guilty, a decision that was subsequently affirmed by the Court of Appeals.

ISSUES:

1. Whether the testimony of Primo Guevarra is unsubstantiated and hearsay due to the absence of the supporting testimony of Elisa Dotenes.

2. Whether the testimony of Anthony Ambrosio is uncorroborated and self-serving due to the lack of presentation of a receipt showing payment to the accused.

3. Whether the testimonies of Primo Guevarra and Anthony Ambrosio should be considered as self-serving evidence and therefore inadmissible.

4. Whether the testimonies of Guevarra and Ambrosio are unsubstantiated and self-serving.

5. Whether the admission and establishment of the amount received by the accused-appellant through her own testimony is sufficient evidence to prove guilt beyond reasonable doubt.

RULING:

1. The Court finds that the issues raised by Omictin are factual issues. As a general rule, the Court does not review factual findings made by the trial court and affirmed by the appellate court. The exceptions to this rule are not present in this case. Therefore, the Court affirms the decision of the trial court, finding Omictin guilty beyond reasonable doubt of the crimes charged.

2. The testimonies of Guevarra and Ambrosio are not considered self-serving evidence. Self-serving statements are those made by a party out of court advocating his own interest, and they are inadmissible because the adverse party is not given the opportunity for cross-examination. However, the testimonies of a party given as a witness in court are considered admissible evidence, provided that they are made under oath and subject to cross-examination.

3. Even if the testimonies of Guevarra and Ambrosio are unsubstantiated and self-serving, it does not affect the case since the accused-appellant admitted and established the substance of their testimonies through her own testimony during trial.

4. The admission and establishment of the amount received by the accused-appellant through her own testimony is sufficient evidence to prove guilt beyond reasonable doubt.

PRINCIPLES:

• The Court does not review factual findings made by the trial court and affirmed by the appellate court, except in certain exceptional circumstances.

• The exceptions to the rule on not reviewing factual findings are: (1) manifestly mistaken, absurd, or impossible inference; (2) grave abuse of discretion; (3) findings grounded entirely on speculations, surmises, or conjectures; (4) misapprehension of facts; (5) findings going beyond the issues of the case and contrary to the admissions of both parties; (6) conclusionary findings without specific evidence citation; (7) overlooking of relevant undisputed facts; and (8) findings based on absence of evidence contradicted by evidence on record.

• Testimonies made by a party in court as a witness are admissible evidence, as long as they are made under oath and subject to cross-examination.

• Admission and establishment of facts by the accused through their own testimony can be sufficient evidence to prove guilt beyond reasonable doubt.