Case Digest (G.R. No. 258753)
Facts:
People of the Philippines v. Lourdes Rivera, G.R. No. 258753, June 26, 2024, Supreme Court First Division, Marquez, J., writing for the Court. The appeal arose from a Court of Appeals (CA) judgment affirming with modification the Regional Trial Court (RTC) conviction of appellant Lourdes Rivera for illegal recruitment in large scale under Section 6 of Republic Act No. 8042 and three counts of estafa under Article 315, paragraph 2(a) of the Revised Penal Code.Private complainants Michael Silva, his sister Michelle Silva, and their mother Teresita De Silva testified they were introduced to Rivera by an agent, Rosaida Resinto, and went to Rivera’s office in Malate to seek placement for jobs in London. Rivera allegedly promised Michael a hotel maintenance job in London with a monthly salary of PHP 100,000 and told the complainants they would be deployed within two to three months. Each complainant paid placement fees (PHP 150,000 for Michael and Michelle; PHP 200,000 for Teresita), were given receipts, and were required to undergo trainings and medical examinations; none were deployed and they never recovered the fees.
Rivera denied knowledge of co-accused Josie Poy Lorenzo and Angelita Dayrit, claimed she engaged in other businesses in 2004, and disputed signing the receipts. Rivera, Lorenzo, and Dayrit were charged with illegal recruitment in large scale and multiple counts of estafa; however, only Rivera’s cases proceeded because Lorenzo and Dayrit remained at large and their cases were archived. Rivera was arraigned on February 22, 2006 and pleaded not guilty.
The RTC (Branch 6, Manila; presiding judge Jansen R. Rodriguez) found Rivera guilty of illegal recruitment in large scale and of three counts of estafa, sentencing her to life imprisonment with fine for the illegal recruitment count and imposing penalties for the estafa counts; other counts were archived. Rivera appealed to the CA (Eighth Division). In a June 15, 2021 Decision penned by Justice Ronaldo Roberto B. Martin, the CA affirmed the RTC’s findings but mod...(Subscriber-Only)
Issues:
- Are the factual findings of the RTC and CA entitled to deference by this Court?
- Did the prosecution prove beyond reasonable doubt that Rivera committed illegal recruitment in large scale under RA 8042?
- Did the prosecution prove beyond reasonable doubt that Rivera committed estafa under Article 315(2)(a) of the Revised Penal Code?
- Are the penalties and civil awards imposed by the CA (and as modified by the RTC) correct, including the application of RA 1095...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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