capacity and power to recruit and employ complainant abroad and facilitate the necessary amount to meet the requirements thereof, knowing said manifestations and representation to be false and fraudulent and made only to induce said complainant to give, as in fact, the latter did give and deliver to said accused cash money amounting to P40,000, but said accused, once in possession of the same, with intent to defraud and deceive the herein complainant, did then and there willfully, unlawfully and feloniously misapply, misappropriate and convert [the same] to her own personal use and benefit, [and] despite demands made upon her to return the said amount of P40,000, said accused failed and refused and still fails and refuses to do so, to the damage and prejudice of the complainant in the aforementioned amount of P40,000. Contrary to Law. [2] In Criminal Case No. 2862-V-93: That sometime in May 1993 or thereabouts in Valenzuela, Metro Manila and within the jurisdiction of this Honorable Court, the above-named accused, defrauded and deceived one MARY JANE AQUINO-VILLANUEVA in the following manner to wit: said accused, by means of false manifestations and fraudulent representation made to the said complainant to the effect that she has the capacity and power to recruit and employ complainant abroad and facilitate the necessary amount to meet the requirements thereof knowing said manifestations and representation to be false and fraudulent and made only to induce said complainant to give, as in fact, the latter did give and deliver to said accused cash money amounting to P35,000, but said accused, once in possession of the same, with intent to defraud and deceive the herein complainant, did then and there willfully, unlawfully and feloniously misapply, misappropriate and convert [the same] to her own personal use and benefit, [and] despite demands made upon her to return the said amount of P35,000, said accused failed and refused and still fails and refuses to do so, to the damage and prejudice of the complainant in the aforementioned amount of P35,000. Contrary to Law. [3] In Criminal Case No. 2863-V-93: That sometime in May and June 1993 or thereabouts in Valenzuela, Metro Manila and within the jurisdiction of this Honorable Court, the above-named accused, defrauded and deceived one ARISTON B. VILLANUEVA in the following manner to wit: said accused, by means of false manifestations and fraudulent representation made to the said complainant to the effect that she has the capacity and power to recruit and employ complainant abroad and facilitate the necessary amount to meet the requirement thereof, knowing said manifestations and representation to be false and

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