G.R. No. 132376 - People vs. Angeles y Calma

Accused-appellant Samina Angeles y Calma was charged with four counts of estafa and one count of illegal recruitment.
The five criminal cases, consolidated and tried jointly by the Regional Trial Court of Manila, Branch 50, involved multiple transactions and allegations against the accused.
The charges arose from different incidents in September 1994 in Manila, where complainants alleged they were defrauded by the accused through false pretenses and fraudulent representations.

On or about September 8, 1994, in Manila, the accused allegedly misrepresented her capacity to recruit and employ Maria Tolosa de SardeAa for a domestic helper job in Paris, France.
By means of false statements and fraudulent promises regarding document processing and employment facilitation, the complainant was induced to deliver a total amount of money (initially P107,000.00, followed by additional payments).
The accused, after obtaining the funds, misappropriated and converted them for her personal use, thereby defrauding the complainant.

Allegedly, on the same day (September 8, 1994) in Manila, the accused misrepresented her ability to recruit and employ Marceliano for work in Paris.
The complainant, convinced by the alleged promise and fraudulent representations, provided a sum that totaled P190,000.00.
The accused misappropriated the amount for her own benefit.

On or about September 9, 1994, the accused was charged with defrauding Precila by falsely indicating her ability to secure a contract worker placement in Canada.
Precila delivered the amount equivalent to US$2,550.00 (P61,200.00 in Philippine Currency) based on these representations.
The accused allegedly misused the amount rather than processing the travel documents as promised.

In an incident during the first week of September 1994 in Manila, the accused purportedly induced Vilma Brina to pay an amount equivalent to US$2,550.00 (P61,200.00 in Philippine Currency) by falsely representing her ability to process travel documents.
Although this complaint was included, Vilma Brina did not testify in court, leading to issues regarding the proof of the alleged estafa for this count.

The accused was accused of recruiting workers for overseas employment without securing the necessary license or authority from the Department of Labor and Employment.
She allegedly promised placement abroad to several individuals (Marceliano T. Tolosa, Precila P. Olpindo, Vilma S. Brina, and Maria Tolosa de SardeAa y Tablada) for a fee.
This recruitment was conducted without the requisite government authorization, falling under the ambit of illegal recruitment as defined under Article 38 of the Labor Code.

The complainants, primarily Maria Tolosa de SardeAa and Marceliano T. Tolosa, indicated that their decision to transact with the accused was significantly influenced by instructions and advice from their relatives already abroad.
Meetings occurred at the Expert Travel Agency on Mabini Street, Manila, where the accused requested payment for the processing of travel documents and related travel requirements.
Testimonies from the complainants revealed that their relatives had introduced the accused and provided assurances regarding employment opportunities abroad.
Cross-examination of witnesses emphasized that the complainants were already predisposed to leave for employment abroad based on prior communications with their relatives, thereby casting doubt on the extent of representations made directly by the accused.

In her defense, the accused claimed she was merely a marketing consultant and international trade fair organizer, not a recruiter.
She maintained that she assisted only in the processing of travel documents and did not guarantee employment; the promises of jobs abroad were attributed to the instructions of the complainants’ relatives.
The trial court initially convicted her on the estafa counts and the illegal recruitment count with corresponding penalties and orders to indemnify the complainants.
Notably, there was inconsistency between the amounts testified by the complainants and those alleged in the Information among the various cases.

Whether the evidence presented by the prosecution established, beyond reasonable doubt, that the accused fraudulently induced the complainants to part with their money by misrepresenting her capacity to recruit or secure employment abroad.

Was there a demonstration of deceit regarding the processing of travel documents versus a promise of employment?
Did the complainants’ reliance on the representations pivot solely on the accused’s statements or also on pre-existing communications with their relatives?

Whether the prosecution sufficiently proved the elements of illegal recruitment, specifically:

That the accused acted without the valid license or authority required by law.
That she engaged in acts constituting recruitment and placement which would normally involve a promise or offer of employment.

Whether the element of deceit, a principal component of the crime of estafa, was present considering the testimonies and admissions of the complainants that indicate prior predisposition towards going abroad based on instructions from relatives.
Whether the discrepancies between the amounts stated in the Information and those testified by complainants affected the determination of the quantum of damage for the estafa counts.