G.R. No. L-15388 - Anderson vs. Perkins

Republic Act No. 7610 (Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act), Republic Act No. 9262 (Anti-Violence Against Women and Their Children Act of 2004), and the Supreme Court’s Rule on Violence Against Women and their Children contain confidentiality provisions aimed at protecting the dignity and privacy of women and children victims.
A letter from a mother of a child-abuse victim prompted the Supreme Court to reconsider posting full texts of child sexual-abuse decisions on its Internet Web Page. The Court required comments from the Office of the Solicitor General (OSG), the Integrated Bar of the Philippines (IBP), National Press Club (NPC), Philippine Press Institute (PPI), Kapisanan ng mga Brodkaster sa Pilipinas (KBP), and the Department of Social Welfare and Development (DSWD).
The OSG, DSWD, KBP, and NPC all advocated strict confidentiality and proposed pseudonyms or coding of victim information. The Supreme Court resolved to withhold real names of women and children victims and to use fictitious initials instead.

On November 8 and 13, 1998, appellant Melchor Cabalquinto allegedly raped his eight-year-old daughter (“AAA”) inside their residence in Quezon City by force and intimidation, undressing her, achieving carnal knowledge against her will.
AAA’s mother (“ABC”) discovered the November 13 incident by peeping through a door gap, saw Cabalquinto on top of AAA, confronted him, and then sought advice and reported to barangay officials, the police, and the Child Protection Unit (CPU) of Philippine General Hospital, where AAA underwent a medical examination.
ABC and AAA executed sworn statements; two Informations for rape were filed (Criminal Case Nos. Q-98-79683 and Q-98-79684). Cabalquinto pleaded not guilty.

The Regional Trial Court (RTC), Quezon City, Branch 87, convicted Cabalquinto of two counts of rape, sentenced him to death under Art. 335 of the Revised Penal Code as amended by RA 7659, and ordered him to pay AAA P75,000.00 in civil indemnity per count.
On automatic review, the Supreme Court required briefs, then, pursuant to People v. Efren Mateo, transferred the case to the Court of Appeals (CA).
The CA affirmed the RTC decision, added P50,000.00 moral damages and P25,000.00 exemplary damages per count.
The Supreme Court again took up the case for final disposition.

Should the Supreme Court continue posting full texts of decisions in child sexual-abuse cases on its Web Page, given statutory confidentiality provisions and the victims’ reasonable expectation of privacy?
Whether the evidence—victim’s testimony, mother’s observation, and medical findings—sufficiently establishes that Cabalquinto committed rape on November 8 and 13, 1998.
What is the appropriate penalty in view of Republic Act No. 9346 abolishing the death penalty?
What civil and other damages should be awarded to the victim?