Case Summary (G.R. No. 200884)
Applicable Law
The case involves violations of the Migrant Workers and Overseas Filipinos Act of 1995 (Republic Act No. 8042), particularly concerning illegal recruitment, as defined under Section 6 of the Act, and estafa under Article 315 of the Revised Penal Code (RPC).
Charges and Proceedings
Salvatierra was charged with illegal recruitment in large scale and several counts of estafa. The Information claimed that she unlawfully recruited individuals for overseas employment as factory workers in South Korea for fees that exceeded legal limits and resulted in their failure to secure deployment despite payments made. During the trial, the prosecution established that Salvatierra represented herself as having the capability to deploy the victims abroad and received substantial fees without the proper licensing.
Defense and Trial Outcome
Salvatierra denied the allegations and claimed to be a victim herself of a different consultancy. Nevertheless, the RTC convicted her on October 10, 2008, sentencing her to life imprisonment for illegal recruitment and varying prison terms for the estafa charges based on the amounts defrauded. Her defense was not deemed credible, as substantial evidence indicated her role in receiving money under false pretenses.
Appeals and Appellate Court Decision
Upon appeal, the Court of Appeals (CA) upheld the RTC's decision while modifying the fine for the illegal recruitment offense and revising the penalties for the estafa cases. The CA concluded that Salvatierra's actions constituted both illegal recruitment in large scale and estafa, affirming her guilt beyond a reasonable doubt.
Elements of the Crimes
For illegal recruitment, the prosecution needed to prove:
- Engagement in recruitment activities without a valid license.
- Recruitment against three or more persons.
- The intent to deceive and defraud intended victims.
For estafa, the essential elements included defrauding victims through deceitful means, which resulted in financial loss.
Penalties Imposed
Given the large-scale nature of the illegal recruitment—which is classified as an offense involving economic sabotage—Salvatierra was sentenced to life imprisonment an
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Case Background
- The appeal originates from the Court of Appeals (CA) Decision dated June 3, 2011, in CA-G.R. CR-HC No. 03687.
- The case involves Mildred M. Salvatierra, who was charged with Illegal Recruitment in Large Scale under Section 6 of Republic Act No. 8042.
- The allegations detail that from March to October 2004, Salvatierra misrepresented herself as capable of recruiting Filipino workers for employment abroad, specifically in South Korea, and collected substantial fees from multiple complainants without the necessary license.
Charges and Allegations
- Salvatierra was charged with:
- Illegal Recruitment in Large Scale: Promising employment for fees ranging from P49,500 to P97,500, all while lacking the required licensing from the Department of Labor and Employment.
- Estafa: Eight separate counts of swindling various individuals through deceitful claims of her ability to deploy them abroad, resulting in financial losses to each complainant.
Procedural History
- The Regional Trial Court (RTC) rendered a joint decision finding Salvatierra guilty on both counts.
- She pleaded not guilty to all charges upon arraignment, leading to a trial where the prosecution presented evidence through the testimonies of the victims who testified about their dealings with her.
Evidence Presented
- Victims testified that they were induced to pay placement fees based on Salvatierra's false representations.
- Receipts and petty cash vouchers issued by Sa