Case Digest (G.R. No. 145734-35)
Facts:
People of the Philippines v. Vicenta Medina Lapis, Angel Mateo, Aida de Leon (at large) and Jean Am-amlaw (at large), G.R. Nos. 145734-35, October 15, 2002, the Supreme Court Third Division, Panganiban, J., writing for the Court.The two Informations (both dated April 20, 1999) charged the four accused with syndicated illegal recruitment under Republic Act No. 8042 and with estafa under Article 315(2)(a) of the Revised Penal Code. The complainants were Melchor F. Degsi and Perpetua L. Degsi. At the time of the trial, appellants Vicenta Medina Lapis and Angel Mateo were in custody and arraigned; Aida de Leon and Jean Am-amlaw were at large (their cases were ordered sent to the archives by the trial court to be revived upon arrest or surrender).
At the Regional Trial Court (RTC) of Makati City, Branch 138 (Judge Sixto Marella Jr.), the prosecution presented the complainants and a corroborating witness (Priscilla Marreo), documentary evidence and a stipulation that the accused had no POEA license. The complainants testified they were recruited in Baguio by Am-amlaw, brought to Manila to meet de Leon, who introduced them to Mateo as a contact who could send them to Japan; Mateo allegedly showed documents and extracted multiple payments totaling P158,600 as processing and placement fees. Lapis (introduced as Mateo’s wife) allegedly assisted in processing and solicited further payments, including amounts for plane tickets and travel taxes. Documentary exhibits included unofficial receipts in Mateo’s handwriting and various papers shown to the victims.
The defense denied recruitment activity and claimed business dealings in importation; Mateo introduced import-related documents and both he and Lapis denied soliciting or receiving the disputed funds as alleged. Both appellants pleaded not guilty and were represented by court-appointed counsel.
The RTC convicted Lapis and Mateo: in Criminal Case No. 99-1112 (RA 8042) it found them guilty of illegal recruitment and sentenced them to life imprisonment and to fines of P1,000,000 each (last paragraph, Sec. 7, RA 8042), and ordered indemnity and reimbursements; in Criminal Case No. 99-1113 (estafa) it imposed twenty years’ reclusion temporal. The RTC orde...(Pro-only)
Issues:
- Was syndicated illegal recruitment under Section 6 of RA 8042 proven beyond reasonable doubt?
- Was conviction for estafa under Article 315(2)(a) of the Revised Penal Code proven beyond reasonable doubt?
- Should Vicenta Medina Lapis have been convicted as a co-conspirator (i.e., did the evidence establish her participation beyond mere knowledge or acquiescence)?
- What modifications, if any, should be made to the RTC’s penalty and damages awards (including interest and a...(Pro-only)
Ruling:
- (Pro-only)
Ratio:
- (Pro-only)
Doctrine:
- (Pro-only)