GR 132895; (March, 2004) (Digest)
G.R. No. 132895 ; March 10, 2004
PEOPLE OF THE PHILIPPINES, appellee, vs. ELIZABETH CASTILLO and EVANGELINE PADAYHAG, appellants.
FACTS
Appellants Elizabeth Castillo and Evangeline Padayhag were charged with Qualified Kidnapping and Serious Illegal Detention for the abduction of five-year-old Horacio Cebrero IV “Rocky” on March 1, 1995, in Parañaque, Metro Manila, for the purpose of extorting ransom. The prosecution established that Padayhag fetched Rocky from his home under a pretext, and they met Castillo at a McDonald’s. The child was then taken to a house where he was detained. Rocky’s father, Luis Cebrero, received ransom calls demanding money, including a specific instruction to deliver cash at a location in Bulacan. Authorities, after a stakeout, rescued Rocky and arrested Castillo at the ransom drop-off point.
ISSUE
The core issue is whether the guilt of both appellants for the crime of Qualified Kidnapping and Serious Illegal Detention was proven beyond reasonable doubt.
RULING
The Supreme Court MODIFIED the trial court’s decision. It AFFIRMED the conviction of Elizabeth Castillo but REVERSED the conviction of Evangeline Padayhag, acquitting her. For Castillo, the Court found the prosecution evidence conclusive. The victim, Rocky, positively identified Castillo in court as one of the women who took and detained him. This testimony was clear and credible, given without hesitation. Crucially, Castillo was caught in the act by police officers during the ransom payment operation in Bulacan, providing direct evidence of her participation in the extortion scheme, which qualified the kidnapping.
For Padayhag, the Court ruled that the evidence against her was insufficient to sustain a conviction beyond reasonable doubt. While Rocky identified her in court, his testimony regarding her specific role was inconsistent and lacked the requisite clarity and certainty needed for a capital offense. The Court emphasized that in cases where the penalty is death, the proof of guilt must be based on the strength of the prosecution’s evidence, not the weakness of the defense. The prosecution failed to present corroborative evidence, such as the testimony of the housemaid Rosanna Baria who allegedly handed Rocky to Padayhag, to solidify its case against her. This failure created reasonable doubt, warranting her acquittal. Castillo was sentenced to death, while Padayhag was ordered released.