Case Digest (G.R. No. 248567) Core Legal Reasoning Model
Facts:
The case involves Erwin Torres y Castillo (petitioner) and an unnamed minor, referred to as AAA (respondent), concerning charges filed on October 14, 2012, in Quezon City, Philippines. Torres was accused of violating Section 5(b) of Republic Act No. 7610, known as the "Special Protection of Children Against Abuse, Exploitation and Discrimination Act.” The incident occurred at Torres’ residence, where he allegedly sexually abused AAA, his 12-year-old stepdaughter, by forcing her into a series of acts that he presented as a request for a massage. Testifying under oath, AAA recounted that upon entering his room, Torres locked the door and began to strip her of her clothing while performing sexual acts against her will. She stated that this was not an isolated incident since Torres had previously subjected her to unwanted advances, including inappropriate touching.
AAA's mother, BBB, corroborated her daughter’s allegations, explaining that she evicted Torres from their hom
... Case Digest (G.R. No. 248567) Expanded Legal Reasoning Model
Facts:
- Background of the Case
- Erwin Torres y Castillo (petitioner) was charged with violating Section 5(b) of Republic Act No. 7610 – the “Special Protection of Children Against Abuse, Exploitation and Discrimination Act.”
- The charge alleged that on October 14, 2012, in Quezon City, Torres, by force and intimidation, committed acts of child abuse against AAA, a 12-year-old minor, his stepdaughter.
- The alleged acts included embracing the minor, removing portions of her clothing (shirt, bra, shorts, and panty), forcibly laying her down, touching her breasts, and coercing her into further inappropriate actions—all of which were claimed to debase and demean her intrinsic dignity.
- Allegations and Testimonies
- Prosecution’s Version
- AAA testified that Torres, her stepfather, invited her to his room under the pretext of giving a massage.
- Once inside, Torres locked the door and turned off the lights, then ordered AAA to remove her bra and shirt.
- He is alleged to have touched her breasts and even uttered instructions for further sexual acts, which she refused.
- AAA further alleged that Torres had been molesting her since 2011, particularly when she was near the kitchen sink.
- Testimonies of Other Witnesses
- BBB, AAA’s mother, testified that she had evicted Torres from their home upon discovering the incidents and mentioned that Torres later sought forgiveness through text messages.
- Aida Maria H. Perez, a psychiatrist, also testified in support of the prosecution’s narrative.
- Defense’s Version
- Torres, being the sole defense witness, denied the allegations and claimed that he was at home preparing for a birthday after-party that involved several family members.
- He contended that he never asked AAA for a massage and noted critiques related to AAA being opposed to his marriage to BBB.
- Proceedings in the Lower Courts
- Regional Trial Court (RTC) Proceedings
- During the trial, the RTC of Quezon City, Branch 107, acquitted Torres for failure of the prosecution to establish guilt beyond reasonable doubt.
- The RTC found AAA’s testimony inconsistent—pointing to discrepancies between her affidavit and her direct in-court testimony—and held that the evidence fell short of the required standard.
- Additionally, the RTC noted the lack of evidence on the element of coercion or influence, which is necessary in cases involving minors not exploited in prostitution.
- Court of Appeals (CA) Proceedings
- AAA pursued a petition for certiorari under Rule 65 before the CA, challenging the RTC’s acquittal.
- On March 7, 2019, the CA annulled the RTC’s decision, finding Torres guilty beyond reasonable doubt of lascivious conduct under Section 5(b) of R.A. 7610.
- The CA sentenced Torres to reclusion perpetua without eligibility for parole, imposed a fine of ₱15,000.00, and ordered payment of moral and exemplary damages amounting to ₱75,000.00 each.
- Post-CA Developments
- Torres filed a motion for reconsideration, which was denied on July 24, 2019.
- Torres then filed a Petition for Review on Certiorari under Rule 45 of the Rules of Court, arguing that the CA’s reversal of the acquittal violated his constitutional right against double jeopardy.
Issues:
- Constitutional Issue on Double Jeopardy
- Whether the Court of Appeals violated Torres’ constitutional right against double jeopardy by convicting him for lascivious conduct under Section 5(b) of R.A. 7610 despite an earlier acquittal by the RTC.
- Whether the alleged misappreciation of evidence by the RTC constitutes a “grave abuse of discretion” sufficient to pierce the finality-of-acquittal rule.
- Procedural and Evidentiary Concerns
- The issue of whether the inconsistencies pointed out in AAA’s affidavit and her direct testimony justify overturning the trial court’s acquittal.
- Whether the procedural mechanism used by AAA (a petition for certiorari) was proper given that only the Office of the Solicitor General has standing to challenge an acquittal in criminal cases.
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)