Case Summary (G.R. No. 207811)
Applicable Law
This case is governed under the 1987 Philippine Constitution and relevant provisions of the Labor Code and Republic Act No. 8042 (Anti-Illegal Recruitment Act), which define illegal recruitment and set forth penalties for violations.
Background of the Charges
In Criminal Case No. 07-1399, it was alleged that from April to June 2006, Molina, authorized by the Department of Labor and Employment, unlawfully recruited complainants for overseas employment, collected substantial placement fees from them, and failed to deploy them or reimburse their expenses despite obligations incurred. In Criminal Case No. 07-3108, a similar modus operandi was applied, where co-accused Vincent Zulueta, whose case was archived due to being at large, worked with Molina to recruit complainants for factory jobs in Korea while failing to deploy them.
Trial and Evidence Presented
During the trial, significant testimony came from the complainants who recounted their experiences and interactions with Molina and Zulueta. For instance, complainants Escobar, CariAo, and Aragon indicated that they were each promised deployment in Korea within three months from their payment of PHP 75,000.00 as a placement fee. Evidence included cash vouchers from the SCLMC, affirming receipt of their respective fees. However, after months of waiting with no deployment, the complainants reported Molina to the authorities, leading to her arrest.
Accused-Appellant's Defense
Molina denied all allegations of illegal recruitment, claiming that SCLMC had a valid operation license and asserting that no recruitment occurred during the aforementioned period due to a temporary suspension imposed by the Philippine Overseas Employment Administration (POEA). She contended that the complainants, motivated by malice from a third party, falsely accused her of illegal activities.
Regional Trial Court's Decision
The RTC found Molina guilty in Criminal Case No. 07-1399 and Criminal Case No. 07-3108, sentencing her to life imprisonment and a fine of PHP 500,000.00 for the former and a shorter prison term and fine for the latter. The court emphasized that the complainants' testimonies effectively established Molina’s guilt as all elements of illegal recruitment were satisfied, including the lack of valid license and the deceptive collection of fees.
Court of Appeals' Findings
On appeal, the CA affirmed the RTC’s decision but modified the penalty in Criminal Case No. 07-3108, rectifying the sentencing framework stipulating penalties prescribed under R.A. 8042. The appellate court upheld the findings of the lower court regar
...continue readingCase Syllabus (G.R. No. 207811)
Case Background
- This case is an appeal from the Decision dated December 14, 2012, of the Court of Appeals, which affirmed with modifications the Decision dated May 31, 2010, of the Regional Trial Court (RTC), Branch 143, Makati City.
- The case involves two counts against accused Delia Molina for illegal recruitment: Criminal Case No. 07-1399 (illegal recruitment in large scale) and Criminal Case No. 07-3108 (illegal recruitment).
Criminal Charges
Criminal Case No. 07-1399:
- Accused Molina, authorized by the Department of Labor and Employment, recruited several individuals for overseas employment, promising them jobs in Korea and collecting a placement fee of P75,000.00 each.
- The individuals, including Anthony Galiste, Romulo Nones, Elisa Escobar, Geraldine CariAo, Diony Aragon, Maribel Rosimo, Gilbert Rosimo, and Eric Valdez, were not deployed despite payment.
Criminal Case No. 07-3108:
- In this case, along with co-accused Vincent Zulueta (whose case was archived), Molina allegedly recruited Cecille Bartolome and others, promising them employment for a fee of P225,000.00 without delivering on the promise.
Criminal Case No. 08-066:
- This case involved a separate charge of illegal recruitment where Molina was also accused of promising jobs to Leo John Alday and Rosemarie Respueto, in exchange for placement fees, which were also not honored.
Trial Proceedings
- Appellant pleaded not guilty at the arraignment. The trial commenced, featuring testimonies from multiple complainants who detailed their interactions with Molina and Zulueta at the SCLMC office.
- Prosecution's Witnesses:
- Elisa Escobar, Geraldine CariAo, and Diony Aragon testified about being promised jobs in Korea by Mo