PEOPLE v. JULIA REGALADO ESTRADA

FACTS:

The case involves the prosecution of Julia Regalado Estrada for illegal recruitment in large scale and three counts of estafa. Three private complainants, Noel Sevillena, Albert Cortez, and an unnamed individual, testified that they were recruited by Estrada for overseas employment in Dubai. They claimed that Estrada represented herself as having the power and authority to deploy workers abroad and demanded payment for processing fees and other documents. Sevillena and Cortez paid a total of P29,000 each to Estrada and were instructed to go to the recruitment agency, ABCA, to complete their requirements. However, when they went to ABCA, they were informed that Estrada was not connected to the agency and that their requirements were not submitted.

In defense, Estrada denied the allegations and claimed that the private complainants were part of a scheme orchestrated against her. She mentioned that she merely mentioned ABCA and Worldview International Corporation because she knew their respective owners. She also denied receiving any money from the private complainants and claimed that she did not recruit them for overseas work.

After trial, the Regional Trial Court (RTC) found Estrada guilty of illegal recruitment in large scale and three counts of estafa. The RTC ruled in favor of the private complainants, finding their testimonies to be credible and persuasive. The Court of Appeals (CA) affirmed the RTC's decision, stating that the private complainants' testimonies prevailed over Estrada's denial. Dissatisfied with the rulings, Estrada appealed the decision to the Supreme Court, claiming that the prosecution failed to establish the necessary elements of the offenses beyond a reasonable doubt.

ISSUES:

  1. Whether the trial and appellate courts erred in finding Estrada guilty of illegal recruitment in large scale despite the prosecution's failure to prove the essential elements of the crime by proof beyond reasonable doubt.

  2. Whether the trial and appellate courts erred in finding Estrada guilty of estafa despite the prosecution's failure to prove the essential elements of the crime by proof beyond reasonable doubt.

RULING:

The appeal lacks merit.

  1. Illegal Recruitment in Large Scale

    • Ruling: The Court is convinced that the prosecution was able to establish the essential elements of the crime of illegal recruitment in large scale.

      • Estrada was not licensed or authorized to recruit workers for overseas employment.

      • Estrada unlawfully engaged in recruitment and placement activities.

      • Estrada committed illegal recruitment activities against three or more persons.

  2. Estafa

    • Ruling: The Court sustains Estrada's conviction for three counts of estafa under Article 315(2)(a) of the RPC. The elements required for estafa were duly established:

      • Estrada made false representations of her authority to deploy the complainants for overseas employment.

      • The complainants parted with their money based on these false representations, resulting in damage.

PRINCIPLES:

  1. Elements of Illegal Recruitment in Large Scale (R.A. No. 8042)

    • The offender has no valid license or authority required by law to engage in recruitment.

    • The offender undertakes recruitment and placement activities as defined in the Labor Code.

    • Recruitment activities are committed against three or more persons.

  2. Elements of Estafa (Article 315(2)(a) of the RPC)

    • The accused defrauded another by abuse of confidence or by means of deceit.

    • The offended party suffered damage or prejudice capable of pecuniary estimation.

  3. Doctrine on Double Jeopardy and Multiple Convictions

    • A conviction for illegal recruitment does not preclude punishment for estafa, as both crimes are penalized under different laws and involve distinct elements.

CONCLUSION

Estrada's convictions for illegal recruitment in large scale and multiple counts of estafa are affirmed, but penalties for estafa are modified based on new legislation (R.A. No. 10951).