Title
Cadajas y Cabias vs. People
Case
G.R. No. 247348
Decision Date
Nov 16, 2021
A 24-year-old man was convicted for inducing a 14-year-old girl to send explicit photos via Facebook Messenger, violating anti-child pornography laws, despite claims of a consensual relationship.

Case Digest (G.R. No. 247348)
Expanded Legal Reasoning Model

Facts:

  • Relationship between Petitioner and AAA
    • Petitioner Christian Cadajas y Cabias (petitioner), then 24 years old, worked in a canteen where he met AAA, a 14-year-old girl.
    • After initial reluctance, petitioner and AAA exchanged Facebook Messenger messages, became sweethearts on April 2, 2016, and maintained a virtual relationship.
  • Discovery and Evidence Gathering
    • In June 2016, BBB (AAA’s mother) learned of the relationship by accessing AAA’s Facebook account on her cellphone.
    • On November 18, 2016 at around 5:30 AM, BBB found messages in which petitioner coaxed AAA to send nude photos of her breasts and vagina.
    • AAA sent the photos; when she attempted to delete the conversation, BBB forced her to reopen petitioner’s Messenger to copy the chat transcript and images.
  • Criminal Charges and Trial Court Proceedings
    • On December 27, 2016, two informations were filed in RTC Valenzuela City:
      • Criminal Case No. 215-V-17 (RA 7610 violation) for coercing AAA to send nude photos.
      • Criminal Case No. 216-V-17 (child pornography under RA 10175 in relation to RA 9775) for inducing AAA to create child pornography via Messenger.
    • Petitioner pleaded not guilty to both charges.
    • RTC acquitted petitioner in Case No. 215-V-17 but found him guilty in Case No. 216-V-17, sentencing him to reclusion temporal and a ₱1,000,000 fine.
    • On appeal, the CA affirmed the conviction for child pornography, modifying the penalty to 14 years, 8 months, 1 day to 18 years, 3 months, plus the same fine.
  • Supreme Court Proceedings
    • Petitioner filed a Rule 45 petition before the Supreme Court, challenging:
      • Admissibility of Messenger chat (right to privacy).
      • Characterization of his acts as child pornography.
      • Interpretation of Section 4(c)(2) RA 10175 and related RA 9775 provisions.
      • Sufficiency of proof beyond reasonable doubt.
    • The CA denied his motion for reconsideration on May 9, 2019.

Issues:

  • Whether the Messenger chat transcript and photos are inadmissible as fruit of the poisonous tree, violating petitioner’s right to privacy.
  • Whether petitioner’s acts constitute child pornography under Section 4(c)(2) of RA 10175 in relation to Sections 4(a), 3(b), and 3(c)(5) of RA 9775.
  • Whether the CA misinterpreted the scope of Section 4(c)(2) RA 10175 regarding inducement and consent.
  • Whether the evidence establishes petitioner’s guilt beyond reasonable doubt.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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