Case Digest (G.R. No. 222974)
Facts:
Jeffrey Calaoagan v. People of the Philippines, G.R. No. 222974, March 20, 2019, Supreme Court First Division, Gesmundo, J., writing for the Court.
Petitioner Jeffrey Calaoagan was charged by two separate Informations before the Regional Trial Court (RTC) of Rosales, Pangasinan (Criminal Cases Nos. 4877‑R and 4878‑R) with violations of Sec. 10(a) of Republic Act No. 7610 for allegedly physically maltreating two minors, referred to as AAA and BBB, on October 31, 2004. The Informations alleged that petitioner hit AAA with a stone on the left shoulder and punched BBB in the face and head.
At trial petitioner pleaded not guilty. The prosecution presented the private offended parties AAA and BBB and Dr. Raul Castanos, the medico‑legal officer. AAA and BBB testified that petitioner, accompanied by two others, struck them during a midnight encounter; Dr. Castanos testified to findings described as confluent abrasion and soft tissue contusions on AAA and soft tissue contusions on BBB. Petitioner testified that both groups exchanged shouts and that stones were hurled, after which he swung a bamboo stick toward the minors, claiming he did not know whom he actually hit; his sister later reported the incident to police.
The RTC, in a November 5, 2012 Decision, found petitioner guilty beyond reasonable doubt of two counts of Other Acts of Child Abuse under Sec. 10(a), R.A. No. 7610, and imposed indeterminate terms of imprisonment for each count. Petitioner appealed to the Court of Appeals (CA).
In its February 9, 2016 Decision (CA‑G.R. CR No. 35518), the CA affirmed the RTC’s conviction in Criminal Case No. 4877‑R (AAA), awarding moral damages of P20,000 with statutory interest. For Criminal Case No. 4878‑R (BBB), the CA concluded petitioner was guilty only of slight physical injuries under Article 266(1) of the Revised Penal Code (RPC) because it found BBB had already attained majority; it sentenced petitioner to arresto menor and awarded moral and temperate damages.
Petitioner filed a petition for review on certiorari under Rule 45 seeking reversal of the CA decision, arguing the CA gave undue credence to AAA and BBB’s testimonies despite inconsistencies with the medical findings and that the CA erred in its conviction in 4878‑...(Subscriber-Only)
Issues:
- Whether the Court may review the CA’s factual findings in this Rule 45 petition (i.e., whether exceptions to the Rule 45 bar apply).
- Whether the CA gravely erred in affirming the conviction under Sec. 10(a), R.A. No. 7610 in Criminal Case No. 4877‑R (AAA) despite the medico‑legal findings.
- Whether the CA gravely erred in convicting petitioner in Criminal Case No. 4878‑R of slight physical injuries under Article 266(1) of the RPC contrary to the medico‑legal findings and the...(Subscriber-Only)
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)