Case Digest (G.R. No. 115150-55) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
On April 4, 1994, Reydante Calonzo Ya Ambrosio was charged in the Regional Trial Court of Pasig with illegal recruitment in large scale and five counts of estafa, stemming from complaints made by Bernardo Miranda, Danilo de los Reyes, Elmer Clamor, Belarmino Torregrosa, and Hazel de Paula. The trial court found Calonzo guilty of all charges and sentenced him on multiple counts to significant prison terms, a fine of One Hundred Thousand Pesos (P100,000.00), and ordered him to reimburse the complainants various amounts for the sums they had paid in connection with the promised overseas employment. The accused had convinced his victims that he could facilitate their employment in Italy for a considerable fee of P120,000.00 each, making extravagant promises regarding job placements. However, instead of sending them to Italy, he took them to Bangkok, Thailand, where they realized they had been defrauded when he disappeared after collecting additional fees purportedly for visa process Case Digest (G.R. No. 115150-55) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Overview of the Case
- Reydante Calonzo Ya Ambrosio was charged with two sets of offenses:
- Illegal Recruitment in Large Scale.
- Five counts of Estafa, with each count involving separate complainants and different amounts claimed.
- The decision consolidated multiple criminal cases (Crim. Cases Nos. 98850 to 98855) with specified penalties for each offense.
- Details of the Offenses
- Illegal Recruitment in Large Scale
- Calonzo was charged under the provisions regarding illegal recruitment by non-licensees.
- The crime was elevated to “large scale” involvement because it was committed against five persons, constituting economic sabotage.
- The prescribed penalty was life imprisonment, a fine of P100,000.00, and additional costs.
- Estafa
- Five separate counts of estafa were charged against the accused involving different complainants:
- Bernardo Miranda – P120,000.00.
- Danilo de los Reyes – P120,000.00.
- Elmer Clamor – P120,000.00.
- Belarmino Torregrosa – P100,000.00.
- Hazel de Paula – P120,000.00.
- Each count involved the collection of money in exchange for promises of overseas employment, which were never fulfilled.
- The trial court imposed prison terms ranging from prision mayor to reclusion temporal tailored to the amount defrauded in each instance.
- Factual Background and Transactions
- Initial Contact and Promises
- In February 1992, Danilo de los Reyes and his brother-in-law Belarmino Torregrosa met Calonzo at the residence of Loreta CastaAeda in Pasig, Metro Manila.
- Calonzo quickly assured them that he had the capacity to arrange employment abroad—specifically in Italy—for a fee.
- Payment Transactions and Arrangements
- On 13 April 1992, De los Reyes advanced P50,000.00 and pledged a vehicle to meet the processing fee of P120,000.00.
- A scheduled departure for Italy was promised for 29 April 1992; however, the complainants were instead taken to Bangkok on 2 May 1992.
- While in Bangkok, additional sums were extracted purportedly to cover visa and other related expenses.
- Participation of Other Complainants
- Hazel de Paula, Elmer Clamor, and Bernardo Miranda separately availed themselves of Calonzo’s promise in exchange for similar financial commitments.
- Testimonies from all complainants uniformly described being misled by Calonzo’s assertions despite discrepancies such as inconsistent details on dates and amounts.
- Documentary and Testimonial Evidence
- Receipts, allegedly issued by the R. A. C. Business Agency with Calonzo’s signature, were presented as evidence.
- Senior POEA official Nenita Mercado testified that the records clearly showed Calonzo’s business was not licensed for overseas recruitment.
- Loreta CastaAeda’s testimony further corroborated that money collected by the complainants was in fact turned over to Calonzo.
- Defendant’s Version and Defense
- Calonzo acknowledged involvement in a consultancy business through his R. A. C. Business Agency but denied any engagement in recruitment activities.
- He challenged the credibility of the testimonies by citing discrepancies between the amounts collected and those documented in receipts.
- His defense also attempted to introduce testimony regarding an alternative import-export business, which was ultimately held irrelevant to the charges at hand.
Issues:
- Evaluation of Evidence Relating to Illegal Recruitment
- Whether the trial court properly considered the testimony of the POEA employee and evidence showing that Calonzo’s R. A. C. Business Agency was not licensed to recruit workers for overseas employment.
- Whether the acts committed by Calonzo amount to illegal recruitment in large scale under the definition provided by the Labor Code.
- Credibility and Consistency of Witness Testimonies in the Estafa Cases
- Whether the discrepancies between the amounts collected and the receipts presented by complainants provide grounds to discredit their testimonies.
- Whether the positive assertions of the complainants, which were corroborated by documentary evidence and additional witness statements (e.g., Loreta CastaAeda), sufficiently negate Calonzo’s defense of denial.
- Overlapping Offenses and Punishment
- Whether the concurrent conviction for illegal recruitment and multiple counts of estafa, as well as the imposed penalties, are properly calculated and consistent with both the Labor Code and the Revised Penal Code provisions.
- Whether evidence of deceit and misrepresentation supports a conviction under the elements of estafa, specifically abuse of confidence and deceit resulting in pecuniary damage.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)