Case Digest (G.R. No. 198732) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In People of the Philippines v. Christian Caballo (G.R. No. 198732, June 10, 2013), the petitioner, Christian Caballo, then 23 years old, was charged by Information filed on March 16, 1999 (amended May 28, 1999) in the Regional Trial Court (RTC) of Surigao City, Branch 30, with violating Section 10(a), Article VI of Republic Act No. 7610 (RA 7610), the “Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act,” for persuading and inducing AAA, a 17-year-old niece of his choreographer uncle, to have sexual intercourse with him from March to November 1998, resulting in her pregnancy and the birth of a child on March 8, 1999. AAA, then a sophomore at the University of San Carlos boarding in Cebu, met Caballo during the Sinulog Festival in January 1998; their relationship led to multiple sexual encounters in Cebu and Surigao City. At trial, the prosecution presented AAA’s testimony that Caballo promised marriage and assured her he would withdraw to pre... Case Digest (G.R. No. 198732) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Charge and Procedural History
- On March 16, 1999, an Information was filed charging Christian Caballo (23 years old) with violating Section 10(a), Article VI of RA 7610; it was amended May 28, 1999 to include allegations of pregnancy and delivery.
- Upon arraignment, Caballo pleaded not guilty.
- The RTC of Surigao City (Branch 30) in an April 1, 2003 Decision found him guilty under Section 10(a), Article VI of RA 7610 and sentenced him to an indeterminate term (4 years, 2 months, 1 day to 6 years, 8 months, 1 day) plus ₱50,000 moral damages.
- The Court of Appeals (CA), in a January 28, 2011 Decision (denied on reconsideration September 26, 2011), affirmed with modification, convicting him under Section 5(b), Article III of RA 7610.
- Caballo elevated the case to the Supreme Court via petition for review on certiorari.
- Relationship and Alleged Acts
- AAA (17 years old at relevant time) met Caballo in Surigao City through her uncle’s dance troupe; Caballo later visited her in Cebu City in January 1998 and they became sweethearts.
- Between late March and November 1998, Caballo induced AAA to have sexual intercourse on several occasions in Surigao and once in Cebu.
- AAA became pregnant in June 1998 and gave birth on March 8, 1999.
- Prosecution’s theory: Caballo used promises of marriage and assurances of the “withdrawal method,” then encouraged an abortion and later reassured AAA’s mother he would marry her.
- Defense’s theory: AAA was not a virgin, had prior boyfriends, consented as a willing partner, they cohabited briefly, and she rejected his marriage proposals due to studies.
Issues:
- Whether Caballo’s promises of marriage and use of the withdrawal method constitute “persuasion or inducement” amounting to “coercion or influence of any adult” under Section 5(b), Article III of RA 7610.
- Whether, given AAA’s minority, consent is immaterial and the sweetheart defense is inadmissible in child sexual abuse under RA 7610.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)