G.R. No. 206878 - People vs. Caga y Fabre

Appellant Mildred M. Salvatierra was charged with illegal recruitment in large scale under Section 6 of Republic Act No. 8042 (The Migrant Workers and Overseas Filipinos Act of 1995).
The offense allegedly occurred from March 2004 to October 2004 in Mandaluyong City where she represented herself as able to contract, enlist, and transport Filipino workers for employment abroad.
Appellant solicited fees from several complainants, promising deployment to South Korea as factory workers.
She collected specific amounts from each victim (ranging from P49,500.00 to P97,000.00) without securing the necessary license and authority from the Department of Labor and Employment.
Despite receiving payments, she failed to deploy the workers, thereby committing illegal recruitment in large scale as the offense was committed against three or more persons either individually or as a group.

In addition to the illegal recruitment charge, appellant faced eight separate informations for estafa under Article 315(a) of the Revised Penal Code.
The estafa allegations centered on the same set of facts where she induced the complainants by falsely representing her ability to deploy them abroad.
The victims, relying on her representations, parted with their money which was later used by her for personal use.
Specific monetary amounts were detailed for each case (ranging from P49,500.00 to P83,500.00), and in several instances, the case particulars and amounts defrauded were repeated with only the names of the offended parties differing.
The charges indicated that her actions involved deceit or abuse of confidence causing pecuniary damage to the victims.

Following complaints to the National Bureau of Investigation (NBI), an entrapment operation was orchestrated leading to her arrest at a scheduled meeting.
Evidence collected included marked money, receipts, and petty cash vouchers bearing her signature, alongside physical evidence (yellow fluorescent smudges) linking her to the transactions.
During trial, despite her defense that she was merely an applicant and victim of Llanesa Consultancy, the prosecution established her active role in misleading the victims.
The Regional Trial Court (RTC), Branch 211, Mandaluyong City, rendered a decision finding her guilty beyond reasonable doubt for both illegal recruitment and various counts of estafa.
The RTC imposed life imprisonment with fines for illegal recruitment and specified indeterminate sentences (with computed minimum and maximum terms) for each count of estafa.

On appeal, the Court of Appeals (CA) affirmed the RTC decision with modifications in the computation of penalties.
The CA increased the fine for the illegal recruitment offense to P500,000.00 and adjusted the penalty ranges for the estafa counts.
The modifications specifically addressed the computation of indeterminate sentences under the Indeterminate Sentence Law, stipulating adjustments to align with the statutory minimum and maximum periods based on the amounts defrauded.
The CA’s modified decision clarified the appropriate penalty ranges and incremental additions as required by law, ultimately affirming her conviction on all charges except for three counts of estafa where insufficient evidence was found.

Whether appellant’s acts of representing herself as capable of recruiting and deploying workers for overseas employment, without the required license, constitute illegal recruitment in large scale.

Determining if the elements of illegal recruitment under Section 6 of RA 8042 were met.
Assessing if the conduct against three or more persons qualifies the offense as “in large scale.”

Whether the same acts giving rise to the illegal recruitment charge also constitute estafa under Article 315 of the Revised Penal Code.

Examining if there was deceit or abuse of confidence amounting to fraudulent misrepresentation.
Determining if the victims suffered pecuniary damage due to her false representations.

Whether the evidence presented, including marked money, receipts, and witness testimonies, is sufficient to prove appellant’s guilt beyond reasonable doubt in both the illegal recruitment and estafa charges.

Whether the computation of the penalties, particularly the modifications on the minimum and maximum terms for the estafa counts, complies with the guidelines of the Indeterminate Sentence Law.

Evaluating the appropriateness of the RTC’s original penalty computation.
Assessing the CA’s rationale for modifying the minimum term imposed in the estafa cases.

Whether the additional modifications by the appellate court in the computation of penalties (increased fine for illegal recruitment and adjustment of indeterminate sentence ranges for estafa) are consistent with statutory law and judicial precedents.