Case Digest (G.R. No. 132029)
Facts:
- Appellant: Mario Alzona
- Charges: Illegal recruitment in large scale and multiple counts of estafa
- Filing Date: December 4, 1996
- Court: Branch 1 of the Regional Trial Court (RTC) of Manila
- Criminal Case Numbers:
- Illegal Recruitment: 92-113702
- Estafa: 92-113703 to 92-113709
- Case Consolidation: Cases were consolidated and jointly tried.
- Dismissal: Criminal Cases Nos. 92-113703 to 92-113705 dismissed due to the failure of private complainants to testify.
- Prosecution’s Evidence:
- Alzona and his wife promised overseas employment to several individuals in exchange for fees.
- Complainants paid various amounts but were never deployed abroad nor refunded.
- POEA Licensure Officer confirmed Alzona was not licensed to recruit.
- Defense:
- Alzona claimed to be a jeepney driver, not involved in recruitment.
- His daughter and sister supported his alibi.
- Trial Court Decision: Alzona found guilty of illegal recruitment in large scale and four counts of estafa; sentenced to life imprisonment for illegal recruitment and various prison terms for estafa.
- Appeal: Alzona appealed to the Court of Appeals, which affirmed the RTC's decision with a modification in the penalty for one estafa case.
Issue:
- (Unlock)
Ruling:
- The Supreme Court affirmed the Court of Appeals' decision, upholding the trial court's finding that Mario Alzona was guilty of illegal recruitment in large scale.
- The Supreme Court also affirmed the convi...(Unlock)
Ratio:
Illegal Recruitment:
- Prosecution sufficiently proved the elements.
- Credible and consistent testimonies of private complainants.
- Alzona and his wife promised overseas employment without a POEA license.
- Trial court's assessment of witness credibility given deference.
Estafa:
- Evidence for illegal recruitment also showed unity of purpose in defrauding complainants.
- False representations induced complainants to part with their money.
- No reason to overturn the trial court’s credibility findings of prosecution witnesses.
Penalty Modification:
- Cour...continue reading
Case Digest (G.R. No. 132029)
Facts:
The case involves appellant Mario Alzona, who was charged with illegal recruitment in large scale and multiple counts of estafa. The charges were filed on December 4, 1996, before Branch 1 of the Regional Trial Court (RTC) of Manila. The illegal recruitment case was docketed as Criminal Case No. 92-113702, while the estafa cases were docketed as Criminal Cases Nos. 92-113703 to 92-113709. The cases were consolidated and jointly tried. Due to the failure of private complainants to testify, Criminal Cases Nos. 92-113703 to 92-113705 were dismissed against Alzona. The remaining cases proceeded to trial.
The prosecution established that Alzona, along with his wife Miranda (who remains at large), promised overseas employment to several individuals, including Mario Regino Decena, Leonardo Mercurio, Fernando Dela Cruz, and James Mazon, in exchange for substantial fees. The complainants testified that they paid various amounts to Alzona and his wife but were never deployed abroad, nor were their payments returned. A Licensure Officer from the Philippine Overseas Employment Administration (POEA) confirmed that Alzona was not licensed to recruit workers for overseas employment.
Alzona denied the allegations, claiming he was a jeepney driver and was not involved in recruitment activities. His defense included testimonies from his daughter and sister, who corroborated his alibi. Despite this, the RTC found Alzona guilty of illegal recruitment in large scale and four counts of estafa, sentencing ...