Case Digest (G.R. No. 228980) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
The case involves petitioner Marvin Villanueva y Irodistan, who was charged before the Regional Trial Court (RTC) of an undisclosed city for violation of Article III, Section 5(b) of Republic Act (RA) No. 7610, otherwise known as the Special Protection of Children Against Abuse, Exploitation, and Discrimination Act, specifically for committing an act of sexual abuse by lascivious conduct on a minor. The incident occurred on or about November 25, 2010, at around 4:00 p.m. in an overpass in the city. The private complainant, a 15-year-old girl identified as AAA, together with her friend BBB and BBB's 11-year-old sister CCC, were ascending a nonworking escalator when Villanueva allegedly stood behind AAA, lifted her skirt, and touched her buttocks in a lewd manner. BBB witnessed Villanueva approaching AAA and alerted her to hurry. Villanueva was apprehended by a traffic enforcer and subsequently turned over to police officers. Villanueva denied the accusation, claiming he was holdi Case Digest (G.R. No. 228980) Expanded Legal Reasoning Model
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)