People vs. Calonzo

G.R. No. 115150-55 (September 27, 1996)

Reydante Calonzo Ya Ambrosio was convicted of illegal recruitment, estafa, and fined for defrauding victims.

Facts:

Reydante Calonzo y Ambrosio was charged with Illegal Recruitment in Large Scale and five counts of Estafa by several complainants, including Bernardo Miranda, Danilo de los Reyes, Elmer Clamor, Belarmino Torregrosa, and Hazel de Paula. The Regional Trial Court of Pasig found him guilty on April 5, 1994, and imposed various penalties, including life imprisonment for the illegal recruitment charge and significant prison terms for the estafa charges, along with monetary reimbursements to the victims.

The complainants testified that they were lured by Calonzo's promises of employment abroad, particularly in Italy, for a processing fee. Danilo de los Reyes and Belarmino Torregrosa first met Calonzo in February 1992, where he assured them of jobs in Italy. They subsequently paid him a total of P120,000.00, which included a loan against a vehicle. Despite promises of departure, they were instead taken to Bangkok, where they incurred additional expenses and ultimately found themselves abandoned when Calonzo returned to the Philippines.

Other complainants, including Hazel de Paula and Elmer Clamor, similarly testified to having paid Calonzo substantial amounts under the pretense of securing employment abroad. They all later discovered that Calonzo was not authorized by the Philippine Overseas Employment Administration (POEA) to recruit workers for overseas employment.

Calonzo, in his defense, claimed he was not involved in recruitment activities and denied receiving money from the complainants, although he acknowledged that the signatures on the receipts presented by the prosecution resembled his. He argued that the testimonies of the complainants were unreliable and that the POEA employee's testimony supported his claims.

Legal Issues:

  1. Whether Calonzo was guilty of Illegal Recruitment in Large Scale as defined under the Labor Code.
  2. Whether Calonzo was guilty of Estafa based on the elements of deceit and damage to the complainants.

Arguments:

Prosecution:

  • The prosecution presented testimonies from the complainants, who detailed how they were misled by Calonzo into believing they would be employed in Italy, leading them to pay substantial fees.
  • They provided evidence that Calonzo was not licensed to recruit workers, as confirmed by the POEA.
  • The prosecution argued that Calonzo's actions constituted illegal recruitment in large scale, as he engaged in recruitment activities without the necessary authority and targeted multiple individuals.

Defense:

  • Calonzo contended that he was not involved in recruitment and that the complainants' testimonies were inconsistent and unreliable.
  • He claimed that the POEA employee's testimony indicated that he did not process the complainants' applications, which he argued should absolve him of the charges.
  • He denied receiving the amounts claimed by the complainants and suggested that the receipts were not official.

Court's Decision and Legal Reasoning:

The court affirmed the trial court's decision, finding that Calonzo was indeed guilty of Illegal Recruitment in Large Scale and Estafa. The court reasoned that:

  1. The testimonies of the complainants were credible and consistent, demonstrating that Calonzo had engaged in recruitment activities without the necessary license, thus fulfilling the criteria for illegal recruitment as defined in the Labor Code.
  2. The court emphasized that Calonzo's denial of the charges was weak and unconvincing compared to the positive assertions of the complainants, who had no apparent motive to fabricate their claims.
  3. The court also noted that the elements of estafa were satisfied, as Calonzo had defrauded the complainants through deceit, causing them financial loss.

The court highlighted that illegal recruitment in large scale is a serious offense involving economic sabotage, particularly when multiple individuals are victimized. The penalties imposed were deemed appropriate given the amounts involved and the nature of the offenses.

Significant Legal Principles Established:

  • Illegal recruitment is defined broadly under the Labor Code, encompassing various acts of canvassing, enlisting, or promising employment for a fee without the necessary authority.
  • The crime is considered to be committed in large scale when it involves three or more individuals, which was established in this case.
  • The court reaffirmed that the credibility of witness testimonies is paramount, especially when there is no evidence of improper motive to testify falsely.