No, but it's an offence to leave your kids alone at risk. That's law.
Maybe they were aware of the law, but decided it didn't apply in Portugal.
The Portuguese Attorney General referred to the situation regarding the law in Portugal when he decided that ...
SnipIt seems evident to us and because the files contain enough elements for such, that
the crime of exposure or abandonment according to article 138 of the Penal Code can be eliminated from that range:
"1 - Whoever places another person's life in danger,
a) By exposing her in a location where she is subject to a situation from which she, on her own, cannot defend herself against; or
b) Abandoning her without defence, whenever the agent had the duty to guard her, to watch over her or to assist her;"
This legal type of crime is only fulfilled with intent, and this intent has to cover the creation of danger to the victim's life, as well as the absence of a capacity to defend herself, on the victim's behalf.
In the case of the files and facing the elements that were collected it is evident that none of the arguidos Gerald or Kate acted with intent.
The parents could not foresee that in the resort that they chose to spend a brief holiday, they could place the life of any of their children in danger, nor was that demanded from them: it was located in a peaceful area, where most of the residents are foreign citizens of the same nationality and without any known history of this type of criminality.
The parents didn't even represent the realisation of the fact, they trusted that everything would go well, as it had gone on the previous evenings, thus not equating, nor was it demanded from them, the possibility of the occurrence of an abduction of any of the children that were in their respective apartments.
Reinforcing what was said is also the fact that despite leaving their daughter alone with her siblings in the apartment during more or less dilated moments, it is certain that in any case they checked on them.
http://genreith.de/pj-archiving-2008.pdfThat was the Portuguese legal position in 2008 ... what has changed since then to prompt discussion in 2019 ... a podcast?? which I doubt sheds any light on what happened to Madeleine or adds anything to the present day investigations to find her.