Case Digest (G.R. No. 209859)
Facts:
In Eileen P. David v. Glenda S. Marquez, the petitioner, Eileen David, challenged the Court of Appeals’ May 29, 2013 Decision and November 6, 2013 Resolution reinstating two criminal cases—Illegal Recruitment under P.D. No. 442 as amended and Estafa under Article 315(2)(a) of the Revised Penal Code—filed in the Regional Trial Court (RTC) of Manila. In her sworn complaint before the Manila City Prosecutor, respondent Marquez alleged that in March 2005 in Kidapawan City, petitioner represented herself as a licensed recruiter for overseas workers and collected ₱152,670.00 for placement fees, only to deny deployment and refuse reimbursement when the application was denied. Petitioner countered that she was physically in Canada at the material time, that the funds were merely coursed through her to a friend who processed the papers, and that venue lay exclusively in Kidapawan. On December 9, 2008, two Informations for Illegal Recruitment (Criminal Case No. 08-265539) and Estafa (CrimCase Digest (G.R. No. 209859)
Facts:
- Background of the Dispute
- In March 2005 in Kidapawan City, respondent Glenda Marquez alleged that petitioner Eileen David represented she could recruit her for overseas employment (Live-in Caregiver in Canada), demanded and collected Php152,670.00 as placement/processing fees, then failed to deploy Marquez or refund the money.
- Petitioner David countered that she was in Canada at the time (supported by passport entries), never engaged in recruitment, and merely coursed the funds through her account for a Canadian friend who processed Marquez’s papers.
- Procedural History
- December 9, 2008 – Two Informations filed in Manila RTC:
- Illegal Recruitment (P.D. No. 1412, Art. 38[a], in relation to NLC Art. 13 and RA 8042 Sec. 6) for collecting fees without a POEA license.
- Estafa (RPC Art. 315[2][a]) for fraudulent misrepresentations to obtain and convert Php152,670.00.
- April 15, 2009 – Petitioner moved to quash the Estafa Information (no copy of resolution; lack of venue). May 13, 2011 – RTC Branch 55 denied the motion.
- January 26, 2012 – On reconsideration, the RTC granted the quashal of both Informations and recalled warrants for lack of territorial jurisdiction (crimes deemed committed in Kidapawan City).
- March 16, 2012 – RTC denied prosecution’s motion for reconsideration, affirming the dismissal.
- May 29, 2013 – Court of Appeals granted respondent’s petition for certiorari, nullified RTC orders, and reinstated the cases. November 6, 2013 – CA denied petitioner’s motion for reconsideration.
- Petitioner filed a Rule 45 petition for review on certiorari before the Supreme Court, challenging: (a) CA’s acceptance of respondent’s standing; and (b) RTC’s Manila jurisdiction.
Issues:
- Whether the Regional Trial Court of Manila had jurisdiction over the Illegal Recruitment and Estafa cases.
- Whether respondent Glenda Marquez, as private offended party, had legal personality to file a petition for certiorari before the Court of Appeals.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)