Case Digest (G.R. No. 247348)
Facts:
The case involves Christian Cadajas y Cabias (petitioner) and the People of the Philippines (respondent). The events leading to the case began in April 2016 when the petitioner, then 24 years old, started a romantic relationship with AAA, a minor aged 14. Their relationship was discovered by AAA's mother, BBB, in June 2016, when she found messages on her daughter's Facebook account indicating that the petitioner was sexually luring AAA to meet him in a motel. On November 18, 2016, BBB discovered explicit conversations between the petitioner and AAA, where the petitioner was coaxing AAA to send him nude photos of her breasts and vagina. Despite her initial reluctance, AAA eventually sent the requested photos. The petitioner was subsequently charged with violating Section 10(a) of Republic Act (R.A.) No. 7610 and 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. The Regional Trial Court (RTC) acqu...
Case Digest (G.R. No. 247348)
Facts:
Background and Relationship
- Petitioner Christian Cadajas y Cabias, then 24 years old, met the victim, AAA, who was 14 years old, at a canteen where he worked. Their relationship began when AAA’s sibling informed petitioner that AAA had a crush on him. Despite initially avoiding her, AAA began stalking him, and they eventually communicated via Facebook Messenger. After two weeks of courtship, they became sweethearts on April 2, 2016.
Discovery of the Relationship
- In June 2016, BBB, AAA’s mother, discovered their relationship after accessing AAA’s Facebook account on her phone. BBB disapproved of the relationship due to AAA’s age, but the couple ignored her warnings.
Incident of Sexual Solicitation
- In October 2016, BBB read messages where petitioner was luring AAA to meet him in a motel. She confronted petitioner and told him to stay away from AAA.
- On November 18, 2016, BBB found explicit messages between petitioner and AAA, where petitioner coaxed AAA to send photos of her breasts and vagina. AAA complied but later tried to delete the messages. BBB forced AAA to open petitioner’s Facebook Messenger account to retrieve the conversation.
Petitioner’s Admission and Defense
- Petitioner admitted to sending messages like “oo ready ako sa ganyan” and “sige hubad” but denied sending explicit photos of himself. He claimed that AAA asked him to delete their messages and that he broke up with her because her mother disapproved of their relationship.
Criminal Charges
- Petitioner was charged with two offenses:
- Criminal Case No. 215-V-17: Violation of Section 10(a) of R.A. No. 7610 (Special Protection of Children Against Abuse, Exploitation, and Discrimination Act) for coercing AAA to send explicit photos.
- Criminal Case No. 216-V-17: Violation of Section 4(c)(2) of R.A. No. 10175 (Cybercrime Prevention Act) in relation to Sections 4(a), 3(b), and (c)(5) of R.A. No. 9775 (Anti-Child Pornography Act) for inducing AAA to send explicit photos via Facebook Messenger.
Trial Court Decision
- The Regional Trial Court (RTC) acquitted petitioner of the charge under R.A. No. 7610 but found him guilty of child pornography under R.A. No. 10175 in relation to R.A. No. 9775. He was sentenced to reclusion temporal and fined P1,000,000.00.
Court of Appeals Decision
- The Court of Appeals (CA) affirmed the RTC’s decision but modified the penalty to an indeterminate sentence of 14 years, 8 months, and 1 day to 18 years and 3 months, while retaining the fine.
Issue:
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Ruling:
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Ratio:
- Right to Privacy in the Digital Age: The right to privacy is not absolute, especially in cases involving the exploitation of minors. The evidence obtained from petitioner’s Facebook Messenger account was admissible as it did not involve unlawful intrusion.
- Child Pornography as Malum Prohibitum: The offense under R.A. No. 10175 in relation to R.A. No. 9775 is a malum prohibitum, meaning the act itself is prohibited regardless of the perpetrator’s intent or the victim’s consent.
- Inducement of a Minor: The Court emphasized that inducement is present when an adult uses their influence to exploit a minor’s vulnerability, even if the minor appears willing. The age disparity and the nature of the messages demonstrated petitioner’s exploitation of AAA.
- Protection of Minors: The Court underscored the importance of protecting minors from sexual exploitation, as enshrined in R.A. No. 9775 and R.A. No. 10175. The laws aim to safeguard the dignity and development of children, regardless of their perceived maturity or consent.