Case Digest (G.R. No. 252353) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Lina Talocod v. People, G.R. No. 250671 (October 7, 2020), petitioner Lina Talocod was charged via Information dated October 23, 2012 before the Regional Trial Court (RTC) of [City], for violating Section 10(a), Article VI of Republic Act No. 7610 (“Special Protection of Children Against Child Abuse, Exploitation and Discrimination Act”). The accusation stemmed from an incident on November 5, 2011 in [Barangay], wherein petitioner, angered by the 11-year-old minor AAA’s reprimand of another child, allegedly pointed her finger at him and exclaimed: “Huwag mong pansinin yan, at putang-ina yan, mga walang kwenta yan, mana-mana lang yan!” The prosecution maintained that these utterances caused AAA psychological abuse, resulting in nightmares and fear. At the RTC, petitioner was found guilty beyond reasonable doubt and sentenced to an indeterminate penalty of four years, nine months, and eleven days of prision correccional to six years, eight months, and one day of prision mayor, Case Digest (G.R. No. 252353) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Complaint and Allegations
- On October 23, 2012, an Information was filed before the Regional Trial Court (RTC) accusing Lina Talocod of violating Section 10(a), Article VI of Republic Act No. 7610 (Special Protection of Children Against Child Abuse, Exploitation and Discrimination).
- The accusatory portion alleged that on November 5, 2011, petitioner, while angrily pointing her finger at AAA (an 11-year-old child), uttered the words “Huwag mong pansinin yan. At putang ina yan. Mga walang kwenta yan. Mana-mana lang yan!”, thereby subjecting the minor to psychological abuse, cruelty, and emotional maltreatment prejudicial to his natural development.
- Trial Court Proceedings
- Evidence for the Prosecution
- Testimony of AAA describing petitioner’s harsh utterances and his subsequent nightmares and refusal to play.
- No expert testimony on psychological injury; reliance on the child’s own account.
- Defense
- Petitioner claimed she said, “Anak wag mo na patulan yan walang kwenta makipag-away,” addressed to another child (EEE), not to AAA.
- RTC Decision (October 6, 2017)
- Found petitioner guilty beyond reasonable doubt of child abuse under Section 10(a) of RA 7610.
- Sentence: indeterminate imprisonment of 4 years, 9 months, 11 days to 6 years, 8 months, 1 day; moral damages of ₱20,000 with 6% interest.
- Court of Appeals (CA) Proceedings
- Petitioner appealed on grounds of lack of specific intent and absence of expert proof of psychological injury.
- CA Decision (July 30, 2019) affirmed conviction in toto, ruling that (a) intent was immaterial for malum prohibitum offense, and (b) AAA’s testimony sufficed to establish psychological injury.
- Motion for reconsideration denied (November 28, 2019).
- Petition to the Supreme Court
- Petitioner filed a petition for review on certiorari challenging the CA’s affirmation of her conviction.
- The Supreme Court granted full appellate review of the criminal judgment.
Issues:
- Whether the Court of Appeals erred in affirming petitioner’s conviction for violation of Section 10(a), Article VI of RA 7610.
- Whether the element of specific intent to debase, degrade, or demean the intrinsic worth and dignity of a child was established beyond reasonable doubt.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)