Case Digest (G.R. No. 125835) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In G.R. No. 236628, decided January 17, 2023, petitioner Marvin L. San Juan, a Special Police Officer 2, was charged by Information dated July 31, 2014 with threatening the life of AAA, a 15-year-old minor, on March 26, 2014 at a basketball court in Valenzuela City. The Information alleged that an intoxicated San Juan, without justifiable cause, pointed a gun at AAA and chased him with a stone, thereby subjecting the minor to psychological cruelty and emotional maltreatment, in violation of Section 10(a) of Republic Act No. 7610. At the Regional Trial Court (Branch 270), San Juan pleaded not guilty and testified he merely admonished the boys as a police officer, denied brandishing any firearm, and chased them only with a stone. The RTC, crediting the sworn statement of witness BBB, found San Juan guilty of child abuse under Section 10(a) of RA 7610 and sentenced him, on July 22, 2015, to an indeterminate penalty of four years eight months to six years’ imprisonment, plus ₱50,000 Case Digest (G.R. No. 125835) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Procedural Background
- Information dated July 31, 2014 charged SPO2 Marvin L. San Juan (San Juan) with grave threats in relation to Section 10(a), Republic Act No. 7610, for “subjecting said minor to psychological cruelty and emotional maltreatment” by pointing a gun at AAA, 15 years old.
- Arraignment (Aug 26, 2014): San Juan pleaded not guilty; trial on the merits ensued.
- Trial Court Findings (RTC, July 22, 2015)
- Prosecution evidence
- AAA’s sworn narrative: while chatting at a basketball court on March 26, 2014, inebriated San Juan scolded AAA, threatened him with a stone, then pointed a gun and chased him.
- Witness BBB (11 years old): corroborated gun-pointing at AAA’s back, repeated invectives, and pursuit with a stone.
- Defense evidence
- San Juan’s testimony: introduced himself as police, asked the boys not to play early, never drew his gun, chased them only with a stone, and was not drunk.
- RTC Decision
- Convicted San Juan of child abuse under Section 10(a), RA 7610, finding credible gun-pointing testimony; sentenced to an indeterminate term of prision correccional minimum to prision mayor maximum (4 y 8 m to 6 y) and indemnified AAA ₱50,000.
- CA Ruling (May 31, 2017; modified Jan 10, 2018)
- Affirmed RTC’s factual findings; re-designated offense as grave threats in relation to RA 7610.
- Modified penalty to 4 y 9 m 11 d of prision correccional (minimum) to 7 y 4 m 1 d of prision mayor (maximum).
- Awarded AAA moral, exemplary, and temperate damages of ₱20,000 each, plus 6% interest.
- SC Proceedings
- Petition for review on certiorari under Rule 45 assailed CA Decision and Resolution.
- SC granted full briefing and deliberation.
Issues:
- Whether the Court of Appeals erred in finding San Juan guilty of grave threats in relation to Section 10(a) of Republic Act No. 7610 instead of properly classifying and penalizing his act under the law.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)