G.R. No. 225730. February 28, 2018 (Case Brief / Digest)

### Title: People of the Philippines v. Julia Regalado Estrada

### Facts:
Julia Regalado Estrada was charged with Illegal Recruitment in Large Scale and three counts of Estafa in four separate Informations. These charges stemmed from transactions between February and May 2009, where she fraudulently represented to Noel Sevillena, Janice A. Antonio, and Albert M. Cortez her capability to secure overseas employment for them in Dubai for various job positions despite not having the authority or license from the Philippine Overseas Employment Administration (POEA). Estrada pleaded not guilty, and trial on the merits ensued. The private complainants testified that they met Estrada through varying circumstances and were promised overseas employment, resulting in them paying various fees. The defense argued that Estrada merely directed the complainants to recruitment agencies and denied receiving any money or promising employment. The Regional Trial Court (RTC) found Estrada guilty as charged, a decision upheld by the Court of Appeals.

### Issues:
1. Whether Estrada should be found guilty of Illegal Recruitment in Large Scale beyond reasonable doubt.
2. Whether Estrada should be found guilty for three (3) counts of Estafa beyond reasonable doubt.

### Court’s Decision:
The Supreme Court dismissed the appeal, affirming the convictions with modifications due to the amendment of penalties under R.A. No. 10951. It ruled that the essential elements for Illegal Recruitment in Large Scale and Estafa were sufficiently established by the prosecution. For illegal recruitment, Estrada acted without the necessary license and promised employment abroad to more than three persons. Regarding estafa, Estrada misrepresented herself capable of facilitating overseas employment, thereby defrauding the complainants. The penalties were adjusted in accordance with R.A. No. 10951’s amendments to the Revised Penal Code, particularly for the estafa convictions.

### Doctrine:
Illegal recruitment in large scale constitutes economic sabotage and is punishable by life imprisonment and fine when it involves recruitment of three or more persons. Estafa can coexist with illegal recruitment as separate offenses, with convictions under each charge requiring the proof of distinct elements as stipulated under the Revised Penal Code and R.A. No. 8042.

### Class Notes:
1. **Illegal Recruitment in Large Scale** requires: (a) absence of license or authority to recruit for overseas employment, and (b) recruitment of three or more persons. It is considered economic sabotage, invoking the highest penalties under R.A. No. 8042.

2. **Estafa (Art. 315[2][a] RPC)** necessitates: (a) deceit or abuse of confidence, and (b) resultant damage or prejudice. The penalties for estafa have been modified under R.A. No. 10951, adjusting the imprisonable and pecuniary penalties according to the amount defrauded.

3. **R.A. No. 10951** effects: Adjusts the penalties for crimes under the Revised Penal Code to reflect current values, thus impacting sentencing where the amount defrauded dictates the penalty.

4. **Proof Beyond Reasonable Doubt**: For convictions in criminal law, the prosecution must establish the guilt of the accused beyond reasonable doubt through credible and reliable evidence.

### Historical Background:
In the Philippine legal system, illegal recruitment cases emphasize the government’s commitment to protecting its citizens from employment scams particularly targeting individuals seeking overseas work. This case reiterates the stern penalties for those exploiting hopeful job seekers and the judiciary’s role in upholding justice for victims of recruitment fraud.


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