**Facts:** Mary Jane Dela Concepcion y Valdez, also known as “Judith A. Valdez” and “Ofelia Andaya,” was accused of engaging in illegal recruitment activities by promising overseas employment to more than 30 individuals from 2012 to 2014. Dela Concepcion collected over P1,000,000.00 under the guise of processing documents for deployment abroad. She faced charges for several counts of illegal recruitment in large scale under Section 6 of RA No. 8042 as amended by RA No. 10022, and estafa under Article 315, paragraph 2(a) of the Revised Penal Code.
Throughout the judicial process, the Regional Trial Court (RTC) convicted Dela Concepcion of simple illegal recruitment, illegal recruitment in large scale, and estafa, while acquitting her in some cases due to insufficiency of evidence. The Court of Appeals affirmed the RTC’s decision but modified the penalties. Dela Concepcion, arguing that the prosecution failed to prove all elements of the crimes convincingly, elevated the case to the Supreme Court.
**Issues:**
1. Whether Dela Concepcion is guilty beyond reasonable doubt of simple illegal recruitment and illegal recruitment committed in large scale under RA No. 10022.
2. Whether Dela Concepcion is guilty beyond reasonable doubt of estafa as defined under Article 315, paragraph 2(a) of the Revised Penal Code.
**Court’s Decision:**
The Supreme Court denied Dela Concepcion’s appeal, affirming her conviction for simple illegal recruitment, illegal recruitment in large scale, and estafa, with modifications to the penalties imposed. The Court held that the elements of large-scale illegal recruitment and estafa were sufficiently proven. It stressed that the absence of receipts for money paid for recruitment activities was not fatal to prosecution as long as credible testimonial evidence showed Dela Concepcion engaged in illegal recruitment.
**Doctrine:**
– The absence of receipts in illegal recruitment cases is not critical provided the prosecution establishes the accused’s engagement in illegal recruitment through credible evidence.
– The elements of estafa include making false pretenses or fraudulent representations and causing damage to the complainants by deceit.
**Class Notes:**
– **Illegal Recruitment in Large Scale:** Requires (1) engagement in recruitment activities without the necessary license or authority, (2) undertaking such activities against three or more persons, individually or as a group.
– **Estafa:** Committed by (1) using false pretense or fraudulent representation, (2) such falsehood was made prior to or simultaneously with the commission of the fraud, (3) the offended party relied on the false pretense and was induced to part with money or property, leading to (4) damage to the offended party.
**Historical Background:** This case exemplifies the Philippines’ strict stance against illegal recruitment and the exploitation of individuals seeking overseas employment. It highlights the importance of holding individuals accountable for preying on the vulnerabilities of those seeking better opportunities abroad, reinforcing the legal protections established under RA No. 8042 and its amendments.
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