Facts:

• Rosario "Rose" Ochoa was charged with illegal recruitment in large scale and three counts of estafa.
• The case originated from the RTC of Quezon City, Branch 104, which found Ochoa guilty on April 17, 2000.
• The Court of Appeals affirmed the RTC's decision with modifications on March 2, 2006.
• Between February 1997 and April 1998, Ochoa allegedly recruited multiple individuals for overseas employment without a DOLE license.
• Ochoa collected various amounts from the complainants as placement fees but failed to provide the promised jobs.
• Complainants included Robert Gubat, Junior Agustin, Cesar Aquino, and others, who paid amounts ranging from P2,000.00 to P32,000.00.
• Ochoa pleaded not guilty, but the prosecution presented evidence and testimonies from the complainants and a POEA representative, Cory Aquino, leading to her conviction.

Issue:

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Ruling:

1. The Supreme Court upheld the admissibility of the POEA Certification.
2. The Court found no improper shifting of the burden of proof.
3. The evidence was sufficient to find Ochoa guilty of estafa.
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Ratio:

1. Admissibility of POEA Certification:

   • The POEA Certification was admissible as it was an official document issued by a public officer in the performance of duty.
   • Cory Aquino, an officer of the POEA Licensing Branch, verified its authenticity and the procedure followed in its issuance.

2. Burden of Proof:

   • The prosecution successfully proved Ochoa's illegal recruitment activities.
   • The burden of proof did not shift to Ochoa; she failed to rebut the prosecution's evidence convincingly.
   • Testimonies of the complainants and documentary evidence were sufficient to establish her guilt beyond reasonable doubt.

3. Sufficiency of Evidence for Estafa:

   • Ochoa committed estafa by falsely representing herself as capable of providing overseas employment, collecting fees, and failing to fulfill her promises.
   • The elements of deceit and damage were clearly established through the complainants' testimonies and the amounts they paid.

4. Criminal Liability:

   • Ochoa's actions constituted both illegal recruitment and estafa, which are separate o...continue reading