Case Digest (G.R. No. 247348) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Christian Cadajas y Cabias v. People of the Philippines (G.R. No. 247348, 16 November 2021), petitioner Christian Cadajas (24 years old) met the 14-year-old victim, AAA, in Valenzuela City in early 2016 and began a clandestine courtship via Facebook Messenger. Despite AAA’s mother’s (BBB) repeated warnings that AAA was underage, Cadajas persistently exchanged flirtatious messages and on 18 November 2016 coaxed AAA to send nude photographs of her breasts and vagina. AAA initially resisted but ultimately obliged. When AAA tried to erase the chat history, her mother compelled her to reopen it and copied the exchange. Each of them was subsequently charged: (a) under Section 10(a) of RA 7610 (abuse of a minor) and (b) under Section 4(c)(2) of RA 10175 in relation to Sections 4(a), 3(b) and 3(c)(5) of RA 9775 (child pornography via computer system). The Regional Trial Court (RTC) acquitted petitioner under RA 7610 but convicted him under RA 10175/RA 9775, imposing reclusion tempora Case Digest (G.R. No. 247348) Expanded Legal Reasoning Model
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)