G.R. No. 96176 August 21, 1997
PEOPLE OF THE PHILIPPINES, plaintiff-appellee, vs. ZENAIDA ISLA, accused-appellant.

FACTS

Zenaida Isla was charged with Kidnapping for allegedly conspiring to kidnap six-year-old Marites Organez in Manila on April 4, 1987, for the purpose of selling her. The prosecution’s case relied on the following: Amador Organez (the victim’s father) testified that upon arriving home, he was informed his daughter was missing and that a pregnant woman was seen near his house, information he received from neighbors Cristy Manalastas, Julie, and Baby Wycoco. During his search, he met Shirley Martinet and Lola Danding, who each claimed their own missing children were taken by Isla. On July 18, 1987, police informed Amador of Isla’s arrest. Isla then told Amador to go to San Simon, Pampanga to fetch his child. A group including police, Amador, Lola Danding, and Isla went to Pampanga. There, Maura “Orang” Mabalot identified a picture of Maritess as the child Isla brought to her house, stating Isla was looking for someone to adopt the child. Isla then stated she sold the child in Angeles City, but checks at the market there did not locate Maritess. Isla later executed an extrajudicial confession before P/Cpl. Pablito Marasigan, assisted by Atty. Domingo Joaquin of the CLAO, admitting she took Maritess to Teofilo Ablaza for adoption. The defense claimed Isla had no knowledge of the confession’s contents, signed it due to a promise of release, and was not properly assisted by counsel during its preparation. The trial court convicted Isla and sentenced her to life imprisonment.

ISSUE

Whether the trial court erred in convicting the accused based on hearsay evidence, speculations, and an inadmissible extrajudicial confession.

RULING

Yes. The Supreme Court REVERSED and SET ASIDE the trial court’s decision and ACQUITTED Zenaida Isla. The prosecution’s evidence was insufficient to prove guilt beyond reasonable doubt. The testimony of Amador Organez regarding the pregnant woman and Isla’s alleged involvement in other kidnappings was based on hearsay, as he had no personal knowledge. The prosecution’s failure to present the eyewitness neighbors (Cristy Manalastas, Julie, and Baby Wycoco), the victim Maritess Organez (who was reportedly recovered), or any witness to establish Isla’s “notoriety” gave rise to the presumption that their testimony would be adverse to the prosecution. The trial court’s findings were based on possibilities, suspicions, and irrelevant matters, such as other alleged kidnapping cases. Furthermore, the extrajudicial confession was inadmissible. The evidence showed that Atty. Joaquin arrived after the statement was prepared, and Isla was induced to sign with a false promise of release, vitiating her consent. The constitutional rights of the accused were violated. The presumption of innocence was not overcome.