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People of the Philippines v. Elizabeth Castillo G.R. No. 132895.

March 10, 2009

Facts The appellant, Elizabeth Castillo, and co-defendant, Evangeline Padayhag, have been previously charged of kidnapping. The two allegedly conspired to kidnap a certain Luis Cerebro and demanding ransom money for the return of the same, that is, coming to an agreement concerning the commission of a felony and deciding to commit it. In this instant petition for automatic review, the court would like to see if conspiracy did attend the commission of the crime, which gave merit to the previous judgement. Issues Whether or not there was conspiracy to kidnap and extort ransom money. Held No. There was no conspiracy to kidnap and extort ransom money. In so far as the existence of conspiracy is concerned, there must be the sufficient and unbroken chain of events that directly and definitely links the accused to the commission of the crime without space for baseless suppositions or frenzied theories to filter through. Conspiracy is established by the presence of two factors: (1) singularity of intent; and (2) unity in execution of the unlawful objective. In this case, the only participation of Padayhag is to fetch Luis Cerebro from school, not knowing the intent of co-defendant Castillo of kidnapping the same. In so far as extortion is concerned, Padayhags acts of not being in the scene of the taking of the money, and not going with Castillo to dipolog, shows otherwise the conspiracy between them. The supreme court thus affirms the conviction of Elizabeth Castillo, but acquits Evangeline Padayhag.

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