Title
People vs. Sison
Case
G.R. No. 187160
Decision Date
Aug 9, 2017
Erlinda A. Sison, alias "Margarita S. Aguilar," was convicted of illegal recruitment and estafa for falsely promising employment in Australia and misguiding the victim to travel abroad.
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Case Digest (G.R. No. 187160)

Facts:

  • Erlinda A. Sison, also known as "Margarita S. Aguilar," was accused of illegal recruitment and estafa.
  • In late 1999, Darvy M. Castuera was introduced to Sison by her husband, Col. Alex Sison, a police officer.
  • Col. Sison claimed that his wife could facilitate employment papers for workers in Australia.
  • Castuera, influenced by Sison's representations and testimonials, agreed to pay P160,000 for processing his employment as a fruit picker in Australia.
  • On June 16, 2000, Castuera paid Sison P80,000 as a down payment, receiving a signed receipt in return.
  • Sison failed to secure an Australian visa for Castuera, citing difficulties and suggesting travel to Malaysia instead.
  • After multiple travels to Malaysia, Brunei, and Indonesia, Castuera's visa application was denied, leaving him stranded.
  • He sought assistance from the Philippine Embassy to return home and subsequently filed a complaint against Sison and her co-accused with the Philippine Overseas Employment Administration (POEA).
  • The POEA confirmed that Sison and her co-accused lacked the necessary licenses for overseas recruitment.
  • During the trial, Sison denied the allegations, claiming victimization by her co-accused.
  • The Regional Trial Court (RTC) found Sison guilty of illegal recruitment involving economic sabotage and estafa, sentencing her to life imprisonment and a fine of P1,000,000 for illegal recruitment, along with a prison term for estafa.
  • Sison appealed the RTC's decision to the Court of Appeals, which affirmed the RTC's ruling.

Issue:

  • (Unlock)

Ruling:

  • The Supreme Court upheld the Court of Appeals' decision, affirming the RTC's ruling of Sison's guilt for illegal recruitment and estafa.
  • The penalty for illegal recruitment was confirmed, while the penalty for estafa was modifi...(Unlock)

Ratio:

  • The Court determined that Sison's actions constituted illegal recruitment as defined under Republic Act No. 8042, which prohibits recruitment by non-licensees.
  • Evidence indicated that Sison misrepresented her authority to recruit workers for overseas employment, misleading Castuera into believing she could facilitate his job placement in Australia.
  • The Court emphasized that illegal recruitment occurs when an individual creates the i...continue reading

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