Title
People vs. Estrada
Case
G.R. No. 225730
Decision Date
Feb 28, 2018
Julia Estrada convicted for illegal recruitment and estafa after defrauding three individuals by falsely promising overseas jobs without proper licensing.

Case Digest (G.R. No. 225730)
Expanded Legal Reasoning Model

Facts:

  • Indictment and Charges
    • Julia Regalado Estrada was indicted for Illegal Recruitment in Large Scale under Republic Act (R.A.) No. 8042 and for three (3) counts of Estafa under Article 315(2)(a) of the Revised Penal Code (RPC).
    • The charges originated from four (4) separate Informations involving alleged recruitment and fraudulent inducement of three private complainants: Noel Sevillena, Janice A. Antonio, and Albert M. Cortez.
    • Estrada was accused of representing herself as having the authority to recruit and deploy Filipino workers abroad (specifically to Dubai) without a license from the Department of Labor and Employment (DOLE), and defrauding the complainants of large sums of money for fees and processing.
  • Specifics of the Criminal Cases
    • Criminal Case No. 10-278205: Estrada allegedly defrauded Noel Sevillena of PhP61,500 through false representations of her ability to recruit and deploy him as a Master Baker in Dubai.
    • Criminal Case No. 10-278206: Estrada allegedly defrauded Janice A. Antonio of PhP25,000 by falsely promising to recruit and deploy her as a Service Crew in Dubai.
    • Criminal Case No. 10-278207: Estrada allegedly defrauded Albert M. Cortez of PhP37,000 with false promises of recruitment and deployment as a waiter in Dubai.
    • Criminal Case No. 10-278208 (Large Scale Illegal Recruitment): Estrada was charged for recruiting and promising employment abroad without the required license, failing to deploy the complainants, and not reimbursing their incurred expenses.
  • Trial and Evidence for the Prosecution
    • The three private complainants testified that they met Estrada separately from February to April 2009 and were led to believe she could facilitate overseas employment.
    • Estrada was identified by the complainants as the person who received their fees – processing, placement, and medical examination fees – paid personally, without issuing receipts.
    • Estrada required the complainants to undergo medical tests and Pre-Departure Orientation Seminar (PDOS) but ultimately failed to deploy them abroad.
    • The Philippine Overseas Employment Administration (POEA) certified that Estrada was not licensed to recruit overseas workers and was not listed in ABCA International Corporation's employees.
  • Defense Evidence
    • Estrada denied recruiting the complainants and claimed she merely mentioned recruitment agencies (Worldview and ABCA) known to her.
    • She asserted that the complainants sought employment with legitimate agencies and that she did not handle or receive any fees.
    • Emilia G. Cosmo-an, president of ABCA, testified Estrada was not connected with ABCA and her agency never received fees from the complainants.
    • Defense sought to declare Cosmo-an a hostile witness, but the motion was not acted upon by the trial court.
  • Rulings of the Courts
    • The Regional Trial Court (RTC) found Estrada guilty beyond reasonable doubt of illegal recruitment in large scale and three counts of estafa, sentencing her to life imprisonment with fines for illegal recruitment and imprisonment for estafa, plus indemnity to complainants.
    • The Court of Appeals (CA) affirmed the RTC’s decision, emphasizing the credibility of the complainants’ testimony and the absence of a license for Estrada to recruit.

Issues:

  • Whether the trial and appellate courts erred in convicting Julia Regalado Estrada of illegal recruitment in large scale and three counts of estafa despite alleged failure of the prosecution to prove the essential elements beyond reasonable doubt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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