Case Digest (G.R. No. 236628)
Facts:
Marvin L. San Juan v. People of the Philippines, G.R. No. 236628, January 17, 2023, the Supreme Court En Banc, Lopez, J., writing for the Court. Petitioner Marvin L. San Juan (San Juan) – a special police officer – was charged by Information (July 31, 2014) with threatening the life of AAA, then 15 years old, “by poking a gun at him,” thereby subjecting the minor to psychological cruelty and emotional maltreatment, contrary to law. The case proceeded to arraignment (August 26, 2014), trial on the merits, and the RTC hearing of witnesses and the accused’s testimony.At trial the prosecution presented AAA (the victim) and BBB (a then‑11‑year‑old witness). AAA described that while sitting with friends at a basketball court, an inebriated San Juan scolded them, threatened he would “pag-uuntugin ang magulang,” and then pointed a gun at AAA and said he wanted to “pusasan” him. BBB testified he saw San Juan draw and point a gun at AAA’s back; AAA corroborated that he turned and saw the gun. San Juan testified he had identified himself as a police officer, admonished the boys for playing at that hour, denied pointing a gun (saying he left it at home), admitted chasing them with a stone but denied drunkenness. The RTC observed witness demeanor and credited the prosecution’s witnesses.
The RTC (Branch 270, Regional Trial Court) rendered a Decision dated July 22, 2015, convicting San Juan of Child Abuse under Section 10(a) of R.A. No. 7610, and sentenced him to an indeterminate penalty (minimum four years eight months to six years maximum) and ordered indemnity of ₱50,000. On appeal, the Court of Appeals in CA‑G.R. CR. No. 38091 (Decision May 31, 2017; Resolution Jan. 10, 2018) affirmed the RTC’s factual findings but modified the conviction’s nomenclature to Grave Threats in relation to R.A. No. 7610, imposed a different indeterminate penalty and awarded moral, exemplary and temp...(Pro-only)
Issues:
- Did the Court of Appeals err in finding Marvin L. San Juan guilty of grave threats in relation to Section 10(a) of Republic Act No. 7610...(Pro-only)
Ruling:
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Ratio:
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Doctrine:
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