Title
Villanueva y Irodistan vs. People
Case
G.R. No. 228980
Decision Date
Jan 22, 2024
Marvin Villanueva was found guilty of lascivious conduct against a minor, touching her buttocks in public. The CA upheld the RTC's ruling, modifying the sentence to 14 years and 8 months of imprisonment and fines.

Case Digest (G.R. No. 228980)
Expanded Legal Reasoning Model

Facts:

  • Filing of Information and Charges
    • On November 25, 2010, Marvin Villanueva y Irodistan was accused of violating Article III, Section 5(b) of Republic Act (RA) No. 7610, specifically engaging in lewd conduct against a minor, AAA, who was 15 years old at the time.
    • The specific acts charged were that Villanueva, with lewd design, pulled up AAA's skirt and touched her buttocks, constituting sexual abuse.
  • Prosecution Evidence and Narrative
    • Victim AAA, along with her friend BBB and BBB's 11-year-old sister CCC, were returning home from school around 4:00 p.m.
    • They were ascending a nonworking escalator on an overpass when Villanueva allegedly stood behind AAA, lifted her skirt, and touched her buttocks using a mirror.
    • BBB noticed and warned AAA to hurry. AAA confronted Villanueva, who then fled toward the highway.
    • Bystanders heard BBB call for help, thinking Villanueva took AAA’s cellphone.
    • Traffic Enforcer Ronald Tolentino apprehended Villanueva, and police officers later took him to the station for investigation.
  • Defense's Version
    • Villanueva denied the accusations, claiming his hands were full holding two cellphones.
    • He was sent by his mother to buy pancit and boarded a tricycle, dismounting near the escalator.
    • Villanueva saw female students beso-beso and attempted to overtake AAA when someone shouted "Snatcher!"
    • He claimed he ran away fearing assault from the crowd, and that the accusations were false.
  • Trial Court Decision
    • The RTC found Villanueva guilty beyond reasonable doubt and sentenced him to imprisonment of 8 years and 1 day to 17 years, 4 months, and 1 day, plus damages to AAA.
    • The court gave full credence to AAA’s testimony and considered BBB’s corroboration.
  • Court of Appeals Decision
    • The CA affirmed the conviction with modification of the penalty to 14 years and 8 months to 20 years reclusion temporal and increased damages and fines.
    • The CA agreed with the RTC’s findings, including the credibility of AAA and the elements of sexual abuse.
  • Appeal to the Supreme Court
    • Villanueva filed a petition for review, asserting no lewd design and impossibility to commit the act due to holding two cellphones in daylight.
    • Villanueva argued AAA’s age allowed for conditional responsibility, suggesting capacity for fabrication.
    • The People, through the Office of the Solicitor General, contended that the evidence showed moral certainty of Villanueva’s guilt.

Issues:

  • Whether the Court of Appeals correctly affirmed the conviction of Villanueva for lascivious conduct under Article III, Section 5(b) of RA No. 7610.
  • Whether the prosecution sufficiently proved the lewd design and all elements of sexual abuse.
  • Whether Villanueva’s defense of denial and claim of impossibility holds merit.
  • Whether the penalty imposed was proper and commensurate with the offense.

Ruling:

  • (Subscriber-Only)

Ratio:

  • (Subscriber-Only)

Doctrine:

  • (Subscriber-Only)

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