Conviction for BOTH estafa and illegal recruitment

There can be a conviction for both estafa and illegal recruitment. Art. 315, par. 2 (a) of the revised Penal Code, enumerates one of the modes of committing estafa, thus: xxxx2. By means of any of the following false pretenses or fraudulent acts executed prior to or simultaneously with the commission of the fraud: (a) By using fictitious name, or falsely pretending to possess power, influence, qualifications, property, credit, agency, business or imaginary transactions, or by means of other similar deceits.  (G.R. No. 158703. June 26, 2009)

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