Title
Calaoagan vs. People
Case
G.R. No. 222974
Decision Date
Mar 20, 2019
Petitioner convicted of slight physical injuries under RPC for assaulting minors AAA and BBB; intent for child abuse under R.A. No. 7610 not proven.

Case Digest (G.R. No. 222974)
Expanded Legal Reasoning Model

Facts:

  • Antecedents
    • Two Informations were filed against petitioner for violation of Sec. 10(a), R.A. No. 7610 in Criminal Case Nos. 4877-R and 4878-R, charging him with physical maltreatment of minors AAA (15 years old) and BBB (17 years old), respectively.
    • The accusatory portions alleged that on October 31, 2004 at around midnight in Rosales, Pangasinan, petitioner hit AAA on the shoulder with a stone and punched BBB on the face and head, placing them in an embarrassing and shameful situation.
  • Trial Proceedings
    • Petitioner pleaded not guilty and trial ensued before the RTC.
    • The prosecution presented the private offended parties AAA and BBB and Dr. Raul Castaños, medico-legal officer, while the defense offered petitioner’s contrary version.
  • Prosecution’s Version
    • AAA and BBB testified that petitioner, annoyed by them, dragged AAA near the church and struck his right shoulder with a stone; when BBB followed, petitioner punched him on the right cheek.
    • Dr. Castaños’s medical report showed confluent abrasion and soft tissue contusion on AAA’s left shoulder and deltoid area, and soft tissue contusions on BBB’s left periorbital and right occipital-parietal areas.
  • Defense’s Version
    • Petitioner claimed a shouting match ensued between his group and that of AAA and BBB, leading the latter to pelt stones; after police intervention, BBB allegedly wielded a knife toward petitioner’s sister, prompting petitioner to swing a bamboo stick indiscriminately.
    • Petitioner denied knowing whom he hit with the stick and fled when others entered his gate.
  • RTC and CA Rulings
    • The RTC (Nov. 5, 2012) convicted petitioner of two counts of Other Acts of Child Abuse under Sec. 10(a), R.A. No. 7610, sentencing him to indeterminate penalties of prision correccional to prision mayor for each count.
    • The CA (Feb. 9, 2016) affirmed the conviction in Case No. 4877-R (AAA) with P20,000 moral damages but downgraded Case No. 4878-R (BBB) to slight physical injuries under Art. 266(1), RPC, imposing arresto menor and P20,000 moral and P20,000 temperate damages.

Issues:

  • Whether the CA gravely erred in affirming petitioner’s conviction under Sec. 10(a), R.A. No. 7610 in Criminal Case No. 4877-R by fully crediting AAA’s testimony despite discrepancies with medical findings.
  • Whether the CA gravely erred in convicting petitioner of slight physical injuries under Art. 266(1), RPC in Criminal Case No. 4878-R contrary to the medico-legal certificate findings.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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