Case Digest (G.R. No. 240145) Core Legal Reasoning Model
Facts:
This case involves Jaime Capueta y Ataday (petitioner), who was charged with violating Section 10(a) of Republic Act No. 7610 (RA 7610), also known as the Special Protection of Children Against Abuse, Exploitation and Discrimination Act. The charge stemmed from an incident that occurred on or about November 16, 2008, at an unspecified location in the Philippines. The victim, identified by the initials AAA, was a six-year-old minor at the time. According to the prosecution’s evidence, petitioner was at the house owned by his sister where AAA, her brother, and a friend were playing. Petitioner allegedly lifted AAA’s skirt, touched her right thigh and vagina, an act which was deemed to be demeaning and prejudicial to her psychological well-being. AAA reported the incident to her mother BBB, who confronted petitioner but was met with denial and threats. The victim and her mother subsequently reported the incident to barangay authorities. The barangay tanods arrested petitioner and
Case Digest (G.R. No. 240145) Expanded Legal Reasoning Model
Facts:
- Parties and Charges
- Petitioner Jaime Capueta y Ataday was charged with violation of Section 10(a) of Republic Act No. 7610 (RA 7610) via an Information.
- The Information alleged that on or about November 16, 2008, petitioner, with lewd intent, wilfully and unlawfully committed acts of child abuse on AAA, a 6-year-old minor, by touching her legs, arms, and private parts, demeaning and degrading her dignity to her psychological detriment.
- Petitioner pleaded not guilty.
- Incident and Investigation
- On the afternoon of November 16, 2008, AAA and her brother were playing at the foot of the stairs of a house owned by petitioner’s sister. Petitioner came down the stairs and suddenly lifted AAA’s skirt and touched her right thigh and vagina.
- AAA was horrified and ran home crying, immediately reporting the incident to her mother, BBB.
- BBB confronted petitioner, who denied the accusation and threatened her, prompting BBB to bring her daughter to the barangay for an official report.
- Barangay Tanod Arnel Cariaso and others apprehended petitioner and took him to the district hospital for medical examination. Sworn statements of AAA and BBB were executed at the police’s Women and Children’s Protection Desk. Petitioner was turned over to police authorities.
- Trial and Evidence Presented
- Prosecution witnesses: the victim (AAA), her mother (BBB), Barangay Tanod Cariaso, and Police Officer II Rhona Mea Padojinog (testimony stipulated).
- Prosecution presented documentary evidence including:
- Sworn statements of AAA, BBB, and Tanod Cariaso.
- Birth certificate of AAA establishing she was 6 years old at the time.
- Investigation report by PO1 Padojinog.
- Petitioner’s defense: denied the charge, claiming he accidentally hit AAA when he tripped going down the stairs, apologized, and was falsely accused by BBB, who demanded payment and later filed the complaint.
- Decisions Below
- Regional Trial Court (RTC) found petitioner guilty of violation of Section 5(b), Article III of RA 7610 (acts of lasciviousness against a child). RTC imposed a penalty of twelve years, ten months, and twenty-one days to fifteen years, six months, and twenty days reclusion temporal, plus damages to AAA.
- Court of Appeals (CA) affirmed RTC’s decision but modified the penalty to an indeterminate term of twelve years and one day to fifteen years, six months, and twenty days reclusion temporal. The CA upheld AAA’s credibility and ruled petitioner’s denial unconvincing.
Issues:
- Whether the CA erred in affirming the RTC’s ruling finding petitioner guilty beyond reasonable doubt of acts of lasciviousness under Article 336 of the Revised Penal Code, in relation to Section 5(b) of RA 7610.
- Whether the prosecution sufficiently proved the elements of sexual abuse under Section 5(b) of RA 7610, including criminal intent and the nature of the offense properly charged in the Information.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)