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:
- Petitioner: Christian Cadajas y Cabias, a 24‑year‑old man facing criminal charges.
- Respondent: The People of the Philippines, representing the State’s interest in protecting minors.
- It is alleged that Cadajas engaged in a personal and intimate relationship with AAA, a 14‑year‑old minor.
- The relationship was conducted primarily through Facebook Messenger, where explicit, sexually suggestive messages were exchanged.
- Petitioner's communications included explicit textual commands and requests for the minor to send nude photographs of her breasts, vagina, and for her to further expose her body.
- The relationship supposedly developed over several instances, with AAA initiating contact and eventually sending explicit images upon repeated persuasion by Cadajas.
- The minor’s mother (BBB) discovered part of the conversation by accessing the victim’s Facebook account, thereby obtaining a copy of the chat transcript.
- Subsequent events involved AAA’s efforts to delete messages, though a copy of the conversation remained in evidence.
- Cadajas was charged with violating Section 4(c)(2) of Republic Act (R.A.) No. 10175 (the Cybercrime Prevention Act of 2012) in connection with Sections 4(a), 3(b), and 3(c)(5) of R.A. No. 9775 (the Anti‑Child Pornography Act of 2009).
- The lower courts conducted separate proceedings—first in the Regional Trial Court (RTC) and later in the Court of Appeals—where he was found guilty of the child pornography offense.
- While the RTC acquitted him on other charges, it convicted him for the creation of child pornographic material by virtue of inducing the minor to send explicit images.
- A critical piece of evidence was the transcript of the Facebook Messenger conversation, which contained explicit messages exchanged between Cadajas and the minor.
- Petitioner argued that the evidence was obtained in violation of his right to privacy, whereas the trial and appellate courts determined that he had waived timely objection and that the evidence was admissible.
Parties Involved
Nature of the Relationship and Communications
Sequence of Events and Discovery
Criminal Charges and Prosecution
Evidentiary Considerations and Procedural Background
Issue:
- Whether the Facebook Messenger transcript, obtained after BBB accessed the victim’s account, was unlawfully acquired in violation of Cadajas’ right to privacy.
- Whether the failure to object to this evidence in a timely manner constituted a waiver of the privacy claim.
- Whether the evidence conclusively establishes that Cadajas induced or coerced the minor to send explicit photographic images.
- Whether the so‑called “sweetheart defense” (asserting that the relationship was consensual) is a valid defense under the circumstances.
- Whether the communications in question fall within the statutory definitions of child pornography as set forth in R.A. No. 9775 and penalized by R.A. No. 10175.
- How the terms “persuade,” “induce,” and “coerce” should be interpreted in the context of exploiting a minor.
- Whether the imposition of enhanced penalties for crimes committed via a computer system (escalation by one degree) was proper.
- Whether the offense should be considered inherently wrong (mala in se), thus not allowing consent or a sweetheart defense to mitigate criminal liability.
Admissibility of Evidence
Sufficiency of Evidence Concerning Inducement
Interpretation and Application of Statutory Provisions
Penalty and Classification of the Offense
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)