The Supreme Court in People of the Philippines vs. Sonia Valle, G.R. No. 235010, 07 August 2024 held that crimes of illegal recruitment and estafa are two different crimes. A conviction for one does not necessarily mean a conviction for the other. In the same token, an acquittal from one does not necessarily result in an acquittal from the other. As declared by the Court:

“The crimes of illegal recruitment and estafa, while intertwined in many cases of recruitment, have different elements. The penal law on illegal recruitment was enacted specifically as a deterrent to those who conduct recruitment activities without having been previously vetted by the government. It is the commission of acts considered by the law as recruitment activities without possessing the necessary government license or permit which is the essence of the crime. Thus, in previous cases, the Court classified illegal recruitment as malum prohibitum, where intent to deceive, for instance, is immaterial. As a result, even those who are actually capable of sending workers abroad for employment – if their licenses or permits have already expired – may still be liable for illegal recruitment.

On the other hand, the thrust of estafa under Article 315(2)( a) of the Revised Penal Code is broadly to punish those who use deceit such as false pretenses in order to gain something and to cause damage to another.”

In the case of accused Valle, while she was acquitted of illegal recruitment for failure of the prosecution to prove that she had no recruitment license, the Court affirmed her conviction for estafa as it was established that she made false representations that she had the capability to send private complainants to Guam for work, which caused private complainants to part with their money, as payment for supposed placement and processing fees. As it turned out, the accused failed to send private complainants abroad, and private complainants never recovered their money as the accused went into hiding.

Download: https://sc.judiciary.gov.ph/235010-people-of-the-philippines-vs-sonia-valle-y-lapurga/