Title
Supreme Court
Javarez vs. People
Case
G.R. No. 248729
Decision Date
Sep 3, 2020
A public school teacher was acquitted of child abuse charges for pushing a student but convicted of slight physical injuries for hitting another with a broomstick, lacking intent to demean under RA 7610.

Case Digest (G.R. No. 248729)
Expanded Legal Reasoning Model

Facts:

  • Charge, Plea, and Incidents
    • Petitioner Joel C. Javarez, a public school teacher, was charged under two Informations (Criminal Case Nos. 24935 and 24936) with violation of Section 10(a) in relation to Section 31(e) of Republic Act No. 7610 for acts of child abuse and cruelty:
      • Shoving AAA (10-year-old) on February 7, 2008, causing him to fall.
      • Striking BBB (9-year-old) in the face with a broomstick the same day.
    • On arraignment, petitioner pleaded “not guilty.”
  • Prosecution Evidence
    • BBB testified that during a morning review class for the National Admission Test, petitioner hit him with a broomstick handle after BBB’s fight with a classmate over rice pops; medico-legal certificate showed left cheek abrasions and ear hematoma.
    • AAA testified that in the afternoon, petitioner pushed him in the chest when he intervened in a food-related scuffle, causing him to fall face-first; medical exam noted pain and tenderness in the sternal area.
    • Both minors reported the incidents to their parents, filed a complaint with the Department of Social Welfare and Development, and were examined at Brooke’s Point Hospital.
  • Defense Evidence
    • Petitioner claimed he merely intervened to restore order in restless classes and denied any intent to harm; he alleged the children were influenced by AAA’s uncle, the barangay captain.
    • A defense witness asserted that a rooster injured BBB during a cockfight, but this claim was absent in his affidavit and he had no personal knowledge.
  • Lower Courts’ Decisions
    • Trial Court (April 10, 2014) found petitioner guilty on both counts under Section 10(a), RA 7610, sentencing him to prision correctional up to prision mayor and awarding P10,000 civil indemnity and P10,000 damages per victim.
    • Court of Appeals (September 14, 2018) affirmed conviction, held that Section 10(a) covers child abuse/cruelty and other prejudicial conditions, and increased awards to P10,000 civil indemnity, P20,000 moral damages, and P20,000 exemplary damages per victim; denied reconsideration (June 20, 2019).

Issues:

  • Whether the Court of Appeals erred in affirming petitioner’s conviction under Section 10(a), Article VI, of RA 7610 despite alleged absence of intent to debase or demean the children.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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