Case Digest (G.R. No. 173988) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Felina Rosaldes v. People of the Philippines (G.R. No. 173988, October 8, 2014), the petitioner, a public Grade 1 schoolteacher at Pughanan Elementary School in Lambunao, Iloilo, was charged with child abuse under Section 10(a) of Republic Act No. 7610. On February 13, 1996, seven-year-old pupil Michael Ryan Gonzales accidentally bumped the petitioner’s knee as she napped on a bamboo sofa. When he failed to apologize, the petitioner pinched his thigh, lifted him by the armpits and threw him onto the floor, causing him to hit a desk and lose consciousness. She then grabbed his ears and repeatedly slammed him on the floor before returning to teach. Michael Ryan went home in tears and was later examined at Dr. Ricardo Y. Ladrido Hospital, where Dr. Teresita Castigador certified contusions on his ears, thigh and spine, and noted pain on walking. The Regional Trial Court convicted Rosaldes of child abuse on June 26, 2003, sentencing her to an indeterminate term of four years, two Case Digest (G.R. No. 173988) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and background
- Petitioner: Felina Rosaldes, a public schoolteacher at Pughanan Elementary School, Lambunao, Iloilo.
- Victim: Michael Ryan Gonzales, seven-year-old Grade 1 pupil of petitioner.
- Incident and procedural history
- On February 13, 1996, the victim accidentally bumped the teacher’s knee while she was dozing on a bamboo sofa. Petitioner woke up, asked for an apology; when the pupil proceeded to his seat, she pinched his thigh, lifted him by the armpits, slammed him onto the floor against a desk, then grabbed his ears and threw him down repeatedly. The boy lost consciousness.
- The victim’s mother and aunt reported the incident to barangay officials, brought him to Dr. Teresita Castigador at Dr. Ricardo Y. Ladrido Hospital (who certified petechiae and contusions on ears and thigh, lumbar tenderness, painful gait), and filed a complaint.
- Regional Trial Court (Branch 27, Iloilo City) convicted petitioner of child abuse under Section 10(a), RA 7610, sentencing her to 4 years, 2 months, 1 day to 6 years, 1 day, prision correctional/prision mayor. Civil liability was not adjudicated for lack of proof.
- Court of Appeals affirmed on May 11, 2005, dismissing the appeal and modifying the maximum to 10 years, 1 day, prision mayor, based on aggravation for being a public schoolteacher.
- Petitioner’s petition for review on certiorari raised (a) misclassification under RA 7610 vs. RPC and (b) insufficiency of the information violating due process.
Issues:
- Did petitioner’s acts constitute child abuse under Section 10(a) of RA 7610, or only ordinary physical injury under the Revised Penal Code?
- Was the information charging child abuse sufficient in form and substance to satisfy due process?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)