Case Digest (G.R. No. 102984)
Facts:
In Lee Saking y Anniban alias Lee Saking Sanniban v. People of the Philippines (G.R. No. 257805, April 12, 2023), petitioner Lee Saking, also known as Saking, was charged before the Regional Trial Court (RTC), Branch 8, La Trinidad, Benguet, with three offenses: (1) illegal recruitment under Sections 6 and 7 of R.A. 8042 for soliciting and receiving ₱110,000 from Jan Denver Palasi in March 2013 without a license to deploy him as a grape and apple picker in Australia; (2) estafa under Article 315(2)(a) of the Revised Penal Code for inducing Palasi to pay ₱85,000 in July and October 2013 through misrepresentation; and (3) carnapping of Palasi’s Mitsubishi Delica van valued at ₱120,000 in October 2013. Palasi testified that Saking promised overseas employment, collected placement fees in installments without issuing receipts, and wrongfully took his van without consent. The RTC convicted Saking of illegal recruitment and estafa but acquitted him of carnapping. On appeal, the CourtCase Digest (G.R. No. 102984)
Facts:
- Charges against Lee Saking y Anniban
- Illegal recruitment (Criminal Case No. 14-CR-10149) – Alleged misrepresentation as a licensed overseas job recruiter, collection of PHP 110,000 from Jan Denver Palasi as placement fee, and failure to deploy or reimburse.
- Estafa (Criminal Case No. 14-CR-10150) – Alleged false pretenses to induce Palasi to pay PHP 85,000 as processing and related fees for an Australian job, then misappropriation.
- Carnapping (Criminal Case No. 14-CR-10152) – Alleged unauthorized taking of Palasi’s Mitsubishi Delica van valued at PHP 120,000 without owner’s consent.
- Factual narrative
- Palasi met Saking at a car repair shop. Saking offered grape/apple-picking jobs in Australia for a PHP 300,000 placement fee. Palasi, short on cash, offered his van plus PHP 100,000 in cash, paid in three installments, without official receipts.
- Saking purportedly handled paperwork through a “Practice Agency,” made Palasi wait in the car, and failed to submit any application. POEA confirmed Saking had no license.
- Saking took the van from the repair shop without Palasi’s consent; Palasi later recovered it from a third party. Both Palasi and the mechanic testified; the defense presented no evidence.
- Procedural history
- RTC (La Trinidad, Benguet) convicted Saking of illegal recruitment and estafa, acquitted him of carnapping.
- Court of Appeals affirmed the RTC Decision and subsequent Resolution in CA-G.R. CR No. 40287.
- Saking filed a Rule 45 Petition for Review on Certiorari in the Supreme Court, contesting factual findings, the authenticity of the POEA certification, and sufficiency of evidence.
Issues:
- Whether the Court of Appeals correctly affirmed the RTC’s conviction of Lee Saking y Anniban for illegal recruitment and estafa.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)