G.R. No. 151400 - Litton Mills, Inc. vs. Sales

The case involves accused Mary Jane Dela Concepcion y Valdez, also known as “Judith A. Valdez” and “Ofelia Andaya.”
She was charged with several counts, notably simple illegal recruitment, illegal recruitment in large scale (constituting economic sabotage), and estafa.
The allegations arose from her involvement in recruiting individuals for overseas employment in Italy, New Zealand, and other destinations.

In Criminal Case No. 15-316295, Dela Concepcion was accused of illegal recruitment activities via promises of overseas employment, notably as a caregiver in Italy.
In Criminal Case No. 15-316296, along with a co-accused (Vecita Sabacan Villareal, who remains at large), she was charged with multiple counts of illegal recruitment in large scale under Section 6 of Republic Act No. 8042 as amended by Republic Act No. 10022.
Additionally, several counts of estafa under Article 315, paragraph 2(a) of the Revised Penal Code were filed against her based on allegations of defrauding private complainants by collecting fees for processing and deployment documents.
Specific details in the Informations included allegations of:

Collecting placement fees ranging from P15,000.00 to P80,000.00 per individual.
The failure to actually deploy the complainants and the non-reimbursement of fees paid for processing, medical examinations, authentication, and translation of documents.

Meonardo Parial, who testified about being promised employment as a caregiver in Italy and detailed the various payments he made totaling P50,000.00.
Aileene D. Laureano, who claimed that she paid P40,000.00 for processing and deployment and was later unable to contact Dela Concepcion.
Jennifer Portin Laureano, with testimony mirroring that of Aileene, emphasizing the promise of deployment abroad and the subsequent failure to honor such promise.
Mary Grace Dulay, who detailed similar experiences involving various payments made for processing fees and the subsequent non-deployment.
Other testimonies, including that of Oberez, which corroborated the narrative of paying fees based on the promise of deployment.

Evidence presented included acknowledgment receipts (though only one complainant produced such a receipt) and corroborative details regarding payment schedules and follow-up meetings.
Despite the absence of receipts from some complainants, the court noted that testimonial evidence was sufficient to prove the collection of fees and the promise of placements.

During arraignment, Dela Concepcion pleaded not guilty to all charges.
In her testimony, she argued that her role was limited to assisting complainants in processing their documents (medical requirements and Department of Foreign Affairs documents) rather than engaging in actual recruitment.
She claimed that it was her co-accused, Villareal, who was responsible for recruitment activities and that her involvement was solely administrative.
Dela Concepcion admitted to soliciting fees for services such as medical examination and processing of documents but denied promising overseas employment.

The Regional Trial Court (RTC), Branch 15, Manila, rendered a decision convicting Dela Concepcion on multiple counts (illegal recruitment and estafa) and acquitted her in some cases for insufficiency of evidence.
The RTC’s decision specified the penalties, including imprisonment terms varying from twelve years and one day up to life imprisonment and fines ranging from P1,000,000.00 to P2,000,000.00.
The Court of Appeals (CA) subsequently modified some penalties while affirming the convictions.
Dela Concepcion then filed a Notice of Appeal, and the Supreme Court eventually reviewed the case.

The Supreme Court noted that the absence of receipts does not preclude a finding of illegal recruitment if credible testimonial evidence supports the claim, citing People v. Alvarez.
The issues regarding whether the elements of simple illegal recruitment, large-scale illegal recruitment, and estafa were proven beyond reasonable doubt were central to the appeal.
Ultimately, the Court denied the appeal, affirming the convictions while modifying penalty provisions, particularly increasing the fine for large-scale illegal recruitment.

Whether or not the prosecution was able to prove beyond reasonable doubt that:

Accused-appellant engaged in simple illegal recruitment by promising overseas employment without the necessary license or authority.
Accused-appellant committed illegal recruitment in large scale, constituting economic sabotage, against three or more persons individually or as a group.
Accused-appellant committed estafa by means of false pretense, inducing several private complainants to part with money based on fraudulent representations regarding overseas employment.

Whether or not the absence of receipts from some complainants is fatal to the prosecution’s case in establishing illegal recruitment.

Whether the defense’s contention that the accused merely assisted in processing documents could negate the element of fraudulent intent inherent in illegal recruitment and estafa.