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In Cagayan de Oro City, Northstar Overseas Services, Inc. operates without any POEA license. It publicly advertises overseas housekeeping positions for a Gulf country and collects PHP 40,000 from four applicants as processing and placement fees. It issues a Letter of Intent and a purported employment contract from a supposed Gulf hotel that does not exist. No placement ever occurs, and the funds are used to pay the owner's personal debts. Which of the following best describes Northstar's criminal liability under the Revised Penal Code (Arts. 315, 316, and 318) or related statutes?

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Clara

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