FACTS : The case involves accused-appellant Jose Centeno, who, along with several others, was charged with syndicated and large-scale illegal recruitment and multiple counts of estafa for fraudulently recruiting individuals for overseas employment without the required license. Centeno and his co-accused falsely represented that they had the authority to deploy workers abroad, collected substantial placement and processing fees from multiple applicants, and promised deployment on specific dates that never materialized. Despite assurances and collection of fees, the victims were neither deployed nor reimbursed. Witnesses testified that Centeno actively assisted in the recruitment process, providing instructions, facilitating payments, and assuring deployment schedules. A POEA officer confirmed that neither Centeno nor the manpower agency was licensed to recruit. Centeno claimed he was merely an employee and not involved in recruitment, but the court found sufficient evidence of his participation. The RTC convicted him of two counts of syndicated illegal recruitment and three counts of estafa, imposing life imprisonment for the illegal recruitment charges and imprisonment plus restitution for estafa. On appeal, the Court of Appeals affirmed the conviction, modifying only the fines and one penalty. The courts upheld the findings that Centeno, through deceitful representations, defrauded applicants by accepting fees without authority or intention to deploy them, establishing his guilt beyond reasonable doubt.
ISSUE : WON the CA is correct in affirming the RTC's decision
HELD : The Supreme Court affirmed the conviction of Jose Centeno for syndicated illegal recruitment in large scale, constituting economic sabotage, and for multiple counts of estafa, modifying only the penalties for estafa based on Republic Act No. 10951. The Court held that Frontline Manpower Resources & Placement Company had no license to recruit workers, and Centeno, along with others, engaged in recruitment and placement by falsely representing their authority to deploy workers abroad, collecting placement fees, and promising employment which never materialized. These acts satisfied the elements of syndicated and large-scale illegal recruitment as they involved at least three complainants and were committed by a group acting in conspiracy. The same acts also established estafa by deceit because Centeno induced complainants to part with their money through fraudulent misrepresentations, causing them financial damage. For illegal recruitment constituting economic sabotage, the Court maintained the penalty of life imprisonment and fines of ₱500,000. For estafa, the Court applied the amended penalty ranges under RA 10951, reducing the prison terms to an indeterminate penalty of four months of arresto mayor as minimum to one year and eight months of prision correccional as maximum for each count, and ordered payment of actual damages equivalent to placement fees, with legal interest at 12% per annum from February 11, 2008 to June 30, 2013, and 6% per annum from July 1, 2013 until finality, and thereafter 6% until fully paid. The appeal was dismissed for lack of merit, and the modified penalties were imposed accordingly.
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