Case Digest (G.R. No. 247348)
Facts:
Christian Cadajas y Cabias, G.R. No. 247348, November 16, 2021, Supreme Court En Banc, Lopez, J., writing for the Court. Petitioner Christian Cadajas (then 24) was prosecuted by the People of the Philippines for acts arising from his Facebook Messenger exchanges with a 14‑year‑old girl (identified as AAA). The parties began an online courtship in early 2016; AAA’s mother (BBB) later discovered sexually explicit messages in AAA’s account. BBB compelled AAA to open petitioner’s Messenger to copy their conversation and images AAA had sent. AAA testified she sent photos of her breasts and vagina after repeated urging by petitioner.Two informations (filed December 27, 2016) charged petitioner in Criminal Case No. 215‑V‑17 with violating Section 10(a) of R.A. No. 7610 and in Criminal Case No. 216‑V‑17 with child pornography under Section 4(c)(2) of R.A. No. 10175 in relation to Sections 4(a), 3(b) and (c)(5) of R.A. No. 9775. At arraignment petitioner pleaded not guilty. After trial, the Regional Trial Court (RTC), Branch 270, Valenzuela City, acquitted him under R.A. 7610 but convicted him under R.A. 10175/ R.A. 9775, sentencing him to reclusion temporal and a P1,000,000 fine; the RTC reasoned petitioner induced a minor to produce explicit images and characterized the defendant’s conduct as malum prohibitum for R.A. 9775 purposes.
On appeal the Court of Appeals (CA) affirmed the conviction (finding AAA’s minority and inducement established), rejected the “sweetheart” defense, and modified the penalty to an indeterminate term (minimum 14 years, 8 months, 1 day to maximum 18 years, 3 months) while retaining the fine. The CA denied reconsideration (Resolution, May 9, 2019). Petitioner filed a Rule 45 petition for review on certiorari with this Court, contesting (inter alia) admissibility of the Facebook evidence (privac...(Subscriber-Only)
Issues:
- Did the Court of Appeals err in failing to find the Facebook Messenger evidence inadmissible for violating petitioner’s right to privacy?
- Did the Court of Appeals err in convicting petitioner under Section 4(c)(2) of R.A. No. 10175 in relation to Sections 4(a), 3(b) and (c)(5) of R.A. No. 9775 because the acts alleged do not constitute the statutory offense?
- Did the Court of Appeals err in its interpretation of the unlawful and punishable acts under Section 4(c)(2) of R.A. No. 10175 in relation to Sections 4(a), 3(b) and (c)(5) of R.A. No. 9775?
- Did the Court of Appeals err in convicting petitioner despite failu...(Subscriber-Only)
Ruling:
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Ratio:
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Doctrine:
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