Case Digest (G.R. No. 187160) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines vs. Erlinda A. Sison @ “Margarita S. Aguilar”, G.R. No. 187160, decided August 9, 2017, the accused-appellant Erlinda A. Sison was charged with illegal recruitment involving economic sabotage under Sections 6 and 7 of Republic Act No. 8042 (RA 8042) and estafa under Article 315(2)(a) of the Revised Penal Code (RPC). In late 1999, Darvy M. Castuera was introduced to Sison by her husband, Col. Alex Sison of Camp Crame, and his aunt, Edna Magalona. Sison promised to secure for Castuera a fruit-picking job in Australia, showing him photographs and testimonials of supposed recruits. After negotiating a P180,000 fee, later reduced to P160,000, Castuera paid P80,000 as a down payment on June 16, 2000. Despite repeated travels to Malaysia, Brunei, and Indonesia accompanied by Sison and her co-accused Rea Dedales and Leonardo Bacomo, Castuera’s Australian visa was denied. Dedales procured a U.S. visa in an Indonesian passport under a false name and refused to Case Digest (G.R. No. 187160) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Introduction and Agreement
- In late 1999, Darvy M. Castuera was introduced to Erlinda A. Sison by Col. Alex Sison, who mentioned that Sison could facilitate fruit-picker jobs in Australia. During a meeting in Las Piñas, Sison showed Castuera testimonials and photos of purported recruits and promised to handle his visa.
- Sison demanded P180,000 for processing, later reduced to P160,000: P80,000 down payment due before departure, remainder to be deducted from future salary. On June 16, 2000, Castuera paid P80,000 at SM Megamall and received a signed receipt witnessed by his aunt and cousin.
- Overseas Travel and Visa Denials
- On June 28, 2000, Sison and Castuera flew to Zamboanga City, then by boat to Sandakan, Malaysia. After near-overstay incidents in Malaysia and Brunei, they traveled to Indonesia for visa processing, where Sison returned to the Philippines, leaving Castuera with co-accused Rea Dedales and Leonardo Bacomo.
- Castuera’s Australian visa application was denied in Indonesia. Dedales persuaded him to seek a U.S. visa for US$1,000; the visa was issued under an Indonesian name. Castuera’s passport was withheld, extension papers were fake, and he eventually returned to the Philippines at his own expense and filed a POEA complaint.
- Trial Proceedings and Lower Court Decisions
- At trial, Sison claimed she was also a victim recruited by Dedales and denied recruiting Castuera. She asserted Dedales processed her visa and that she merely transferred Castuera’s payments to him.
- The RTC (May 8, 2007) convicted Sison of (a) illegal recruitment involving economic sabotage (RA 8042 §§ 6, 7) and (b) estafa under RPC Art. 315(2)(a), sentencing her to life imprisonment plus fine for recruitment and prision correccional for estafa, with P160,000 indemnity. The CA (Nov. 6, 2008) affirmed.
Issues:
- Whether the prosecution established beyond reasonable doubt that Sison:
- Committed illegal recruitment involving economic sabotage under RA 8042; and
- Committed estafa by deceit under Article 315(2)(a) of the Revised Penal Code.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)