G.R. No. 224610 - Vines Realty Corp. vs. Ret

The Regional Trial Court (RTC), Branch 211, Mandaluyong City, convicted the appellant of illegal recruitment in large scale and five counts of estafa.
The RTC based its conviction on the full faith and credence given to the testimonies of the complainants who testified that the appellant had promised them employment abroad, specifically in Hongkong, in exchange for placement fees.
The trial court found that the appellant represented to the complainants that he possessed the power and ability to deploy them overseas, which later turned out to be a fraudulent representation.
The defenses raised by the appellant, including denial and alibi, were disregarded by the RTC.
For the crime of illegal recruitment, the RTC imposed a penalty of life imprisonment and a fine of P100,000.00.
For the crime of estafa, the RTC imposed indeterminate penalties in five different criminal cases, each involving varying terms of imprisonment and ordered the appellant to indemnify the complainants with specific amounts.

On appeal, the Court of Appeals (CA) upheld the factual findings of the RTC.
The CA agreed that the testimony and evidence sufficiently established all the elements of illegal recruitment as provided under Article 13(b) in relation to Article 34 of the Labor Code.
It held that the appellant’s act of promising employment abroad despite lacking the required license constituted illegal recruitment in large scale and, simultaneously, his false assurances amounted to estafa.

The Supreme Court denied the appellant’s appeal and affirmed his convictions for both illegal recruitment in large scale and estafa.
While upholding the core findings, the Supreme Court modified the penalties specifically imposed for the five counts of estafa.
The modifications involved a recalculation of the penalty ranges based on the Revised Penal Code’s guidelines and the application of the Indeterminate Sentence Law, taking into account the amount defrauded and the prescribed incremental penalty for amounts exceeding P22,000.00.
The detailed computation for each criminal case (MC03-6279 to MC03-6283) was provided, specifying the minimum and maximum terms of imprisonment accordingly.

Whether the elements constituting illegal recruitment in large scale were sufficiently proven, specifically:

The appellant’s undertaking of recruitment activities without the necessary authority or license.
The commission of such activities against three or more persons.

Whether the appellant’s representations and false pretenses concerning his purported power to deploy complainants to Hongkong sufficiently constituted estafa under Article 315(2)(a) of the Revised Penal Code.

The proper division of the prescribed penalty range under the Revised Penal Code.
The determination of the additional penalty based on the difference between the amount defrauded and the threshold of P22,000.00.