Case Summary (G.R. No. 226912)
Charges and Legal Background
Castillo and Padayhag were charged with Qualified Kidnapping and Serious Illegal Detention, as provided under Article 267 of the Revised Penal Code. The prosecution alleges that the accused conspired to kidnap Horacio Cebrero IV, a minor, with the intent to extort ransom. The Regional Trial Court initially imposed the death penalty on the appellants, following a withdrawn guilty plea.
Procedural History
Both appellants were arraigned on May 10, 1995, and initially pleaded guilty but later retracted their pleas, entering not guilty pleas on August 3, 1995. The prosecution presented eight witnesses, including the victim and family members, with Castillo and Padayhag offering only their testimonies in defense.
Prosecution's Version of Events
The prosecution's case outlined the events leading to the kidnapping, beginning with the abduction of five-year-old Rocky Cebrero, who was taken by Padayhag under Castillo's direction. The victim's father received ransom demands for the return of his son, prompting police involvement. The ransom of P800,000 was later dropped off, and Castillo and Padayhag were identified as the individuals who picked it up.
Defense's Position
The defense claimed that Castillo took Rocky not to kidnap him but simply to visit, as she missed him. Padayhag testified that she was misled by Castillo under the pretext of visiting a sick relative. They asserted that no ransom was demanded, and there was no intent to deprive the child of liberty.
Trial Court's Findings
The trial court found the testimonies of the prosecution witnesses credible and established that hazard was posed to the victim, resulting in the conviction of both appellants. It ruled that Castillo's actions were calculated to extort ransom, supported by the substantial evidence connecting her to the crime.
Court of Appeals Findings
Upon review, while the court affirmed Castillo's conviction due to ample evidence of her guilt, it acquitted Padayhag based on her limited involvement and lack of knowledge regarding the criminal intent. The court emphasized that mere participation without knowledge of the conspiracy does not suffice for criminal liability.
Ruling on Penalty and Damages
The Supreme Court confirmed the trial court's imposition of the death penalty on Castillo, yet modifi
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Case Overview
- This case involves an automatic review of the decision by the Regional Trial Court of ParaAque, Branch 260, which found appellants Elizabeth Castillo and Evangeline Padayhag guilty of Qualified Kidnapping and Serious Illegal Detention, sentencing them to death.
- The case revolves around the abduction of a five-year-old child, Horacio Cebrero IV, with the intention of extorting ransom from his parents.
Background Information
- The information filed against Castillo, Padayhag, and a third co-accused, Imelda Wenceslao, accused them of conspiring to kidnap Horacio Cebrero IV in ParaAque, Metro Manila, on March 1, 1995.
- The prosecution's allegation states that the kidnapping lasted more than three days, aimed at extorting ransom to the detriment of the victim and his parents.
Arraignment and Initial Pleas
- Both Castillo and Padayhag initially pleaded guilty on May 10, 1995.
- They later withdrew their guilty plea on May 18, 1995, and entered a plea of not guilty on August 3, 1995.
- Imelda Wenceslao was noted to be at large throughout the proceedings.
Prosecution's Evidence
- The prosecution presented a total of eight witnesses, including the victim, his parents, and various law enforcement officers involved in the case.
- The victim, Horacio, testified about his abduction, identifying the perpetrators and describing the events that transpired.
- Testimonies from family members and law enforcement documented the timeline of the abduction and subsequent ransom demands.
Sequence of Events Leading to the Crime
- On the morning of March 1, 1995, Horacio was fetched by Padayhag, who was inst