Case Summary (G.R. No. 188708)
Arrest and Investigation
On April 1, 1986, Lydia Rama was arrested as a suspected kidnapper in connection with multiple cases of missing children. Following her arrest, Milagros Bungalon, the mother of the missing child, was informed by the police of Rama's custody and subsequently confronted the accused in detention. During this encounter, Rama purportedly disclosed that she had sold Cristina for PHP 400 and indicated that the child was in a dwelling located at the Muslim Center Compound in Quiapo, Manila. Acting on this information, a police raid was conducted later that day, resulting in the recovery of several missing children, including Cristina Bungalon.
Trial Proceedings
Consequently, an information was filed against Lydia Rama and Emelinda D. Renteno for the crime of kidnapping in the Regional Trial Court of Manila. Both accused entered a plea of not guilty. However, proceedings against Renteno were suspended due to her confinement in a mental health facility, thus focusing the trial solely on Rama.
Conviction and Sentencing
On July 20, 1987, the trial court rendered a decision convicting Rama of kidnapping, imposing the penalty of reclusion perpetua and ordering her to pay the costs. Rama's appeal contested the basis of her conviction, asserting that it relied on an extrajudicial confession made without the assistance of counsel.
Evaluation of the Confession
The appellate court examined the appellate claims regarding the alleged extrajudicial confession. It clarified that the conversation between Milagros and Rama could not be classified as an extrajudicial confession since Milagros was not acting as a law enforcement officer but rather as a concerned mother. Moreover, it was established that the conviction did not rely solely on this statement; rather, it was corroborated by the subsequent action taken by the police, who verified the existence of the missing child at the location indicated by Rama.
Legal Implications and Conclusion
The ruling underscored the severity of the crime of kidnapping, particularly when minor children are the victims. The existing penalty for such offenses under Article 267 of the Revised Penal Code
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Case Background
- On March 10, 1986, Cristina Bungalon, a 5-year-old girl, went missing while playing near her residence in Del Pan Tulunan Center, Tondo, Manila.
- Milagros Bungalon, the child's mother, conducted extensive searches for her daughter and reported the disappearance to the police.
- On April 1, 1986, Lydia Rama was apprehended by law enforcement as a suspect in the kidnapping of multiple children.
Arrest and Initial Investigation
- Following her arrest, Milagros Bungalon, along with her mother-in-law, visited Precinct 2 where Rama was detained.
- During this visit, Milagros presented a picture of her missing daughter to Rama.
- Rama allegedly confessed to Milagros that she had sold Cristina for P400.00 and indicated that the child was located in a house within the Muslim Center Compound in Quiapo, Manila.
Recovery of the Victim
- In the afternoon of April 1, 1986, based on Rama's statement, Milagros and her husband, accompanied by the police, conducted a raid on the Muslim Center Compound.
- Several children were successfully recovered from the premises, including Cristina Bungalon, confirming Rama's claim.
Charges and Trial
- As a result of the investigations, an information charge was filed against Lydia Rama and Emelinda D. Renteno for the crime of kidnapping in the Regional Trial Court of Manila.
- Upon arraignment