Case Digest (G.R. No. 173473) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In PEOPLE OF THE PHILIPPINES vs. BETH TEMPORADA (G.R. No. 173473, December 17, 2008), the accused, together with four co-respondents employed by Alternative Travel and Tours Corporation (ATTC), allegedly recruited Filipino workers for overseas jobs without securing a license from the Department of Labor and Employment. From September 2001 to January 2002, at ATTC offices first on Dela Rosa Street, Makati City, and later at Discovery Plaza, Ermita, Manila, they promised Singapore and Hong Kong employment to Rogelio Legaspi, Jr. (technician), Soledad Atle, Luz Minkay, Evelyn Estacio and Dennis Dimaano (factory workers) for fees beyond POEA limits. After receiving passports, application forms, NBI clearances and medical certificates, the group collected P57,600 from Legaspi, P66,520 from Dimaano, P88,520 from Estacio, and P69,520 each from Atle and Minkay. None were deployed nor reimbursed. Separate criminal complaints resulted in six informations dated November 29, 2002: one count Case Digest (G.R. No. 173473) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Background and Incident
- From September 2001 to January 2002, Rosemarie “Baby” Robles, Bernadette Miranda, Nenita Catacotan, Jojo Resco and appellant Beth Temporada, employees of Alternative Travel and Tours Corporation (ATTC), recruited Filipino workers for a fee without POEA license.
- They promised overseas employment to:
- Rogelio Legaspi, Jr. (technician in Singapore)
- Soledad Atle, Luz Minkay, Evelyn Estacio, Dennis Dimaano (factory workers in Hong Kong)
- They collected placement fees ranging from ₱57,600 to ₱88,520 but failed to deploy or refund the complainants.
- Procedural History
- November 29, 2002: Six Informations filed—one for large-scale illegal recruitment (Labor Code Art. 38) and five for estafa (RPC Art. 315(2)(a)).
- Arraignment: Appellant pleaded not guilty; co-accused remained at large.
- May 14, 2004: RTC convicted appellant of all charges—sentenced to life imprisonment + ₱500,000 fine (illegal recruitment) and indeterminate terms for five counts of estafa; ordered to pay actual damages.
- February 24, 2006: CA affirmed RTC, modifying some estafa penalties under the Indeterminate Sentence Law (ISL).
- Supreme Court Review: Appellant challenged sufficiency of evidence and penalty computations.
Issues:
- Whether the evidence was sufficient to convict appellant of large-scale illegal recruitment and five counts of estafa.
- Whether the CA correctly computed the indeterminate penalties for the five counts of estafa under the ISL.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)