Conviction of both illegal recruitment, estafa NOT double jeopardy

It is settled in out jurisdiction that a person who commits illegal recruitment may be charged and convected of illegal recruitment and estafa under paragraph 2(a), Article 315 of the Revised Penal Code, as the former is malum prohibitum where the criminal intent of the accused is not necessary for conviction, while estafa is malum in se where the criminal intent of the accused is necessary for conviction. In short, a conviction for offenses under the Labor Code does not bar punishment for offenses punishable by other laws. [G.R. No. 120389. November 21, 1996]