Case Digest (G.R. No. 127842)
Facts:
People of the Philippines v. Leonora Dulay, G.R. No. 127842, December 15, 2000, Supreme Court First Division, Puno, J., writing for the Court. The accused-appellant is Leonora Dulay; the prosecution is the People of the Philippines.In separate informations filed in the Regional Trial Court (RTC), Tayug, Pangasinan, Branch 52, Dulay was charged with four counts of estafa (Criminal Case Nos. T-1672 to T-1675) and one count of illegal recruitment in large scale (Criminal Case No. T-1676). The estafa informations alleged that Dulay obtained various sums from four complainants — Richard L. Castulo, Eduardo M. Drapeza, Odon V. Orosa and Ricardo C. Ilasin — by means of false representations promising employment in Taiwan and then failed to fulfill those promises or return the money. The illegal recruitment information alleged she recruited those same persons for overseas employment without first securing the requisite license or authority from the Department of Labor and Employment (DOLE/POEA).
At trial the prosecution presented the four complainants and a common witness, Glory Orosa, who testified to the recruitment transactions, the sums paid, and the receipts issued by Dulay (several receipts were marked as exhibits). The complainants described payments for processing fees, plane tickets and medical examinations; some payments were supported by receipts, others were not. The prosecution rested on November 28, 1994. Dulay’s privately retained counsel withdrew for lack of cooperation; a counsel de oficio was appointed, and after Dulay refused to cooperate and the case had been pending long, the trial court declared the case submitted for decision.
The trial court convicted Dulay of illegal recruitment in large scale (Crim. Case No. T-1676) and sentenced her to life imprisonment and a P100,000 fine. It also convicted her of estafa in the fou...(Pro-only)
Issues:
- Was the prosecution’s evidence sufficient to prove beyond reasonable doubt that appellant lacked a license or authority to recruit, an essential element of illegal recruitment in large scale (Crim. Case No. T-1676)?
- Were the estafa convictions (Crim. Case Nos. T-1672–T-1675) properly supported, and were the awards of actual, moral, and exemplary damag...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)